ML20205N013

Rept for South Texas Project Litigation Record Review Program. Related Correspondence

ML20205N013
Person / Time
Site:	South Texas
Issue date:	02/28/1986
From:	S. LEVY, INC.
To:
Shared Package
ML20205N010	List: ML20205N013 ST-HL-AE-1628, Forwards Rept for South Texas Project Litigation Record Review Program & Rept of Senior Advisory Panel Commissioned to Monitor Litigation Record Review Program.Review Methodology Successful.Related Correspondence
References
OL, NUDOCS 8605010259
Download: ML20205N013 (331)

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REPORT FOR THE SOUTH TEXAS PROJECT LITIGATION RECORD REVIEW PROGRAM.

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Prepared for: 1 I

HOUSTON LIGHTING & POWER COMPANY  ;

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FEBRUARY 1986 i 1

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5. LEVY, INCORPORATED 3425 S. Bascom Avenue Campbell, CA 95008 8605050259 860321 PDR ADOCK 05000498-G PDR ' s

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EXECUTIVE

SUMMARY

This Report of the Litigation Record Review Program documents the results and conclusions reached following a systematic review of the record created during the litigation between the Owners of the South Texas Project and the original architect / engineer and constructor of the Project, Brown & Root, Inc., and its parent, Halliburton, Inc.1 The object of the review was twofold: (1) to examine the litigatior, record to determine whether it discloses any .previously unidentified safety-related deficiency in the systems, structures, or components of the South Texas Project or their associated design or quality documents; and (2) to document the review process and its results in a retrievable form. To do this, record documents containing factual information relating to technical aspects of the design and construction--that is, deposition transcripts, answers to interrogatorie-s, and expert reports--

were reviewed.

The review was performed in two stages. First, Houston Lighting &

Power Company employed a screening process to determine which deposi-tions, interrogatories, and expert reports might contain information about technical aspects of South Texas Project design or construction.

Those documents, totaling approximately 100,000 pages, were then transmitted to S. Levy Incorporated for detailed review.

The second stage of the review process consisted of a detailed, line-by-line review by S. Levy Incorporated of all documents identified during the screening process. S. Levy Incorporated recorded each asser-tion in these documents which described a deficiency in systems,.struc-tures, or components; classes of systems, structures, or components; IThe litigation was tentatively settled in May 1985; a final settle-ment was agreed to in December 1985, and the lawsuit was accordingly dismissed.

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processes relating to specific systems, structures, or components; overall South Texas Project site data; or related design or quality documents. A total of 5151 assertions were identified. These asser-tions were then analyzed to determine whether they (1) were not safety-related (and would not adversely affect the operation of safety-related systems, structures, or components); (2) had already been identified by the South Texas Project; or (3) were factually erroneous. The work of identifying and analyzing assertions was performed by engineers experienced in the nuclear power industry, including a number who were specifically knowledgeable about design and construction of the South Texas Project. S. Levy Incorporated expended approximately 30,000 engi-neering manhours on the review program.

The 5151 assertions identified were disposed of as follows: 482 were determined not to be safety-related; the substance of 4662 were shown to have already been identified by the South Texas Project; and 7 were determined to be factually erroneous. The litigation record review disclosed no safety-related deficiencies which had not already been identified for resolution. i More than 70 percent of the assertions were contained in litigation record documents prepared by Houston Lighting & Power Company or Bechtel Power Corporation, including the testimony of Houston Lighting &

Power Company personnel. Most of these assertions were found in record documents which had been prepared with.the aid of engineering personnel from Houston Lighting & Power Company or Bechtel Power Corporation. The-technical areas to which nearly half of the assertions pertained were those in which Bechtel had extensively modified Brown & Root's design.

The absence of previously unidentified safety-related deficiencies was not surprising in light of the earlier comprehensive reviews of the South Texas Project design and construction. In 1979, issues relating to the adequacy of Soil compaction, safety-related concrete placement, ii O

and safety-related welding led to extensive reviews of the majority of in-place safety-related construction. Most safety-related construction was halted until these reviews were completed and the issues had been satisfactorily resolved in 1981.

The changeover of ' responsibilities from Brown & Root, Inc., to Bechtel Power Corporation and Ebasco Services Incorporated cccasioned a thorough review of all Project design and construction. The precise status of engineering and design work had to be ascertained before Bechtel Power Corporation could assume responsibility for existing design and resume design production. Bechtel divided all existing work into " work packages," each covering a plant system, structure, process, or documents. Each package was systematically reviewed, and a report was prepared which described work remaining to be done and any design problems in each package.

In-place construction at the Project was also examined in 1982 by means of a series of "walkdowns" conducted by Bechtel Power Corporation with the aid of personnel from Brown & Root, Inc., and Ebasco Services Incorporated. During these walkdowns, all completed construction at the plant was visually inspected to determine whether or not it conformed to applicable design drawings. The Quality Assurance / Quality Control records applicable to the Project's systems and structures were also reviewed to verify that these records had been properly generated and maintained. Bechtel's engineering review and the walkdowns of in-place construction and related verification of Quality Control records were overseen by the Nuclear Regulatory Commission staff.

The breadth and depth of these reviews made the South Texas Project one of the most closely examined nuclear generating facilities in the United States; the fact that the litigation record review identifie'd no additional safety-related deficiencies was not unexpected in light of these earlier reviews.

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The conduct of the litigation record review was controlled by plans, procedures, and instructions. The overall project was monitored by a Senior Advisory Panel. It was inspected twice by Nuclear-Regulatory Commission Region IV inspectors. The project was also moni-tored on site by Houston Lighting & Power Company's Quality Assurance personnel, as well as S. Levy Incorporated's Corporate Quality Assurance staff. Finally, there were three quality control audits, one conducted by Houston Lighting & Power Company and the other two by an independent auditor commissioned by S. Levy Incorporated. The high level of scru-tiny of the litigation record review by these groups has assured that the review was performed according to its procedures -and that its results are accurate.

In conclusion, the South Texas Project Litigation Record Review Program was a detailed, systematic examination of those portions of the litigation record which were likely to contain assertions of de-ficiencies in systems, structures, or components and their associated design or quality documents. The review did not disclose any previously unrecognized safety-related deficiencies in the South Texas Project's  ;

systems, structures, or components.. The results of the review I demonstrate that any safety-related deficiencies that were asserted in the litigation record have already been identified by Bechtel Power i

Corporation, Ebasco Services Incorporated, or Houston Lighting & Power l l

Company. Given the number and breadth of the allegations arising in the j litigation, this fact underscores the success of the earlier intensive 1

reviews performed on the South Texas Project. l i

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^l TABLE OF CONTENTS D f

Section Title Page i

1 INTRODUCTION ,

1-1 A. HISTORY OF THE SOUTH TEXAS PROJECT l-1 )

1 1.. Background Information 1-1 1

2. Previous Reviews of the South Texas Project Engineering and Construction 1-2

a. The NRC 79-19 Investigation and Related Reviews 1-2 (1) Soils 1-3 (2) Concrete 1-4 1 (3) Welding 1-5

b. Re/iews Related to the Transition i of Responsibilities from Brown & Root, Inc.,

to Bechtel Power Corporation and Ebasco Services Incorporated 1-7 (1) Bechtel Power Corporation's Review of Engineering 1-7 4

(2) Review of In-place Construction by l Bechtel Power' Corporation and  !

Ebasco Services Incorporated 1-9

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l B. THE LITIGATION BETWEEN THE OWNERS OF'THE SOUTH  !

TEXAS PROJECT AND BROWN & ROOT, INC. 1-11 l

1. Brief History of the Case 1-11

2. Issues in the Litigation 1-12

3. The Parties' Major Activities in the Litigation 1-13

a. Discovery 1-13 (1) Interrogatories 1-13 (2) Depositions 1-14 -l (3) Requests for Production of Documents 1-14 v

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TABLE OF CONTENTS (CONTINUED)

Section Title Page 1 INTRODUCTION (CONTINUED)

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B. 'THE LITIGATION BETWEEN THE OWNERS OF'THE SOUTH TEXAS PROJECT AND BROWN & ROOT, INC. (CONTINUED)

3. The Parties' Major Activities in the Litigation (continued)

b. Experts and Expert Reports 1-15

c. Litigation Interface with the Project 1-16 C. HOUSTON LIGHTING & POWER COMPANY'S UNDERTAKING TO REVIEW RELEVANT FARTS OF THE-LITIGATION RECORD l-17 SECTION 1 REFERENCES 1-19 2 PURPOSE OF THE LITIGATION RECORD REVIEW PROGRAM 2-1 3 SCOPE OF THE LITIGATION RECORD REVIEW PROGRAM 1 A. THE LITIGATION RECORD 3-1

1. Complaints, Counterclaims, and Answers 3-1

2. Motions 3-2 J

3. Court Hearing Transcripts 3-2

4. Interrogatory Answers and Respouses to Requests for Admissions 3-2

5. Deposition Transcripts 3-3

6. Expert Reports 3-3

7. Requests for Production of Documents 3-4 B. SCOPE OF THE LITIGATION RECORD REVIEW PROGRAM 3-4 vi

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TABLE OF CONTENTS (CONTINUED)

Section Title Page 4 METHODOLOGY AND PERFORMANCE OF THE LITIGATION RECORD REVIEW PROGRAM 4-1.

A. THE SCREENING PROCESS 4-2

1. Purpose of Screening 4-2

2. Criteria and Methodology of the Screening Process 4-2

a. Interrogatories 4-2

b. Deposition Transcripts 4-3

c. Expert Reports 4-4

3. Checking the Results of the Screening Process 4-4 B. DETAILED REVIEW 0F SELECTED LITIGATION' DOCUMENTS 4-5

1. Introduction 4-5

2. The Litigation Review Team 4-6

a. Technical Participants in the Detailed Review 4-6

b. Training of Technical Participants for the Review 4-7

c. S. Levy Incorporated Computations and Records Centers 4-9

3. Steps in the Detailed Review Process 4-9

a. Line-by-Line Review of Record Documents Identified During the Screening Process 4-9

b. Disposition of Assertions of Deficiency 4-11

c. Second-Level Reviews by Overview Specialists 4-14

d. Administrative Control of S. Levy I Incorporated Review Process 4-15

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4. Completion of the Work and Issuance of the Report 4 l i

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TABLE OF CONTENTS (CONTINUED)

Section Title Page Attach. 4-A OUTLINE OF LITIGATION REVIEW PROCESS 4-A-1 Attach. 4-B CRITERIA FOR SELECTION OF INTERROGATORY ANSWERS FOR REVIEW 4-B-1 Attach. 4-C CRITERIA FOR THE SELECTION OF DEPOSITION TRANSCRIPTS FOR REVIEW 4-C-1 Attach. 4-D CRITERIA FOR SELECTION OF EXPERT REPORTS FOR REVIEW 4-D-1 Attach. 4-E CRITERIA FOR IDENTIFICATION OF ASSERTIONS OF DEFICIENCY 4-E-1 Attach. 4-F CRITERIA FOR SAFETY DETERMINATION 4-F-1 Attach. 4-G CRITERIA FOR DEMONSTRATING STP IDENTIFICATION 4-G-1 Attach. 4-H CRITERIA FOR DETERMINATION ON FACTUAL BASIS 4-H-1 Attach. 4-1 CRITERIA FOR INTERDISCIPLINARY AND SYSTEMS INTERACTION DETERMINATION .4-I-l Attach. 4-J STP LITIGATION REVIEW FORMS 4-J-l Attach. 4-K LITIGATION REVIEW FLOW CHART 4-K-1 5 QUALITY ASSURANCE 5-1 A. INTRODUCTION 5-1 B. 5. LEVY INCORPORATED QUALITY A'SSURANCE 5-1 C. HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE 5-3 D. AUDITS AND INSPECTIONS 5-5

1. S. Levy Incorporated Independent Quality Assurance Audits 5-5

2. Houston Lighting & Power Company Quality Assurance Department Audit 5-6 i

E. OVERALL QUALITY ASSURANCE RESULTS 5-6 Attach. 5-1. LITIGATION RECORD REVIEW QUALITY ASSURANCE ISSUES 5-8 viii S

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TABLE OF CONTENTS (CONTINUED)

Section Title Page' 6 OVERSIGHT BY THE SENIOR ADVISORY PANEL 6-1 A. MEMBERSHIP AND PURPOSE 6-1 B. ACTIVITIES OF THE SENIOR ADVISORY PANEL 6-2

1. October 3, 1985 Meeting 6-2

2. November 15, 1985 Meeting 6-3

3. December 19, 1985 Meeting 6-3

4. January 31, 1986 Meeting 6-3 t

5. Final Meeting

• 6-4 C. SENIOR ADVISORY PANEL CONCLUSIONS '6-4 7 'RESULTS OF THE LITIGATION REVIEW 7-1 A. RESULTS OF THE SCREENING PROCESS 7-1

l. Depositions 7-1

2. Expert Reports 7-1

3. Interrogatories (Including Requests for.

Admissions) 7-2 B. RESULTS OF S. LEVY INCORPORATED DETAILED REVIEW 7-4

1. Identification of' Assertions of Deficiency 7-4

2. Disposition of Assertions 7-9 8 CONCLUSION '8-1 l

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M TABLE OF CONTENTS (CONTINUED)

Section Title Page APPENDIX A- (List of litigation record documents reviewed) A-i 1

! APPENDIX B (List of S. Levy Incorporated Technical Participants in the Litigation-Record Review Program)- B-1 APPENDIX C (Litigation Review Project Procedures) C-i APPENDIX 0 (List of Project documents to be referenced on '

Disposition Forms) 0-1 2

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Section 1 INTRODUCTION A. HISTORY OF THE SOUTH TEXAS PROJECT

1. Background Information1 The South Texas Project (STP or the Project) is a two-unit nuclear generating. station located approximately 15 miles southwest of Bay City, 4 on the west side of the Colorado River, in Matagorda County, Texas.

Each unit is a Westinghouse pressurized water reactor with a rated electrical output of 1250 megawatts. STP is owned jointly by Houston Lighting & Power Company (HL&P), Central Power & Light Company (CP&L),

the City of Austin, and the City of San Antonio. HL&P, as the Project Manager, supervises the construction of STP and is the lead applicant in

the operating license proceeding for the facility. F9el loading at STP is scheduled to take place in sumer 1987 for Unit 1 and in late 1988 for Unit 2.

Brown & Root, Inc., (B&R) was engaged as architect / engineer and constructor for STP in 1972, and design work for the Project commenced that year. HL&P submitted an application for construction permits for the STP on May 14, 1974; the construction permits were issued on December 22, 1975.

B&R remained the architect / engineer and constructor until September 1981, when the Owners announced that it would be removed as architect / engineer. Bechtel Power Corporation (Bechtel) was hired to replace B&R as architect / engineer and construction manager, and tran-4 1I nformation en the history of STP and the STP litigation was drawn from References 1-1 to 1-17 listed at the end of this section. S. Levy Incorporated has performed no independent investigation'into the general history of STP or the STP ligitation.

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sition of Project engineering work from B&R to Bechtel began in October 1981. Although HL&P and the other Owners wished to retain B&R as constructor for STP, B&R declined to remain in that capacity. On February 15, 1982, HL&P announced that Ebasco Services Incorporated (Ebasco) had been selected to replace B&R as constructor.

The replacement of B&R effectively shut down all work at the STP for several months. Bechtel did not resume engineering work on a pro-duction basis until the end of April 1982, and design work in some areas was not resumed until several months later. Much of the safety-related construction had already been halted in late 1979 and early 1980.

Although a limited amount of safety-related work was released for construction while B&R was still on the job, full-scale safety-related construction was not resumed until August 1982, after Bechtel and Ebasco

had started work. Construction not related to safety systems resumed in June 1982.

2. Previous Reviews of the South Texas Profact Engineering and i

Construction The design, engineering, and construction of STP have received un-usually close scrutiny. In addition to normal inspections by the ,

Nuclear Regulatory Commission (NRC), construction of the Project was thoroughly reviewed as an outgrowth of an NRC enforcement action and voluntary stop Work Orders confirmed by the Commission Staff. The change of contractors in 1981 entailed further independent reviews of

• he adequacy of construction as well as design and engineering,

a. The NRC 79-19 investigation and Related Reviews Or. November 10, 1979, the NRC undertook an intensive investigation of QA/QC and related construction activities at STP, especially in the areas of structural backfill, concrete placement, and welding. The results of the investigation were documented in Investigation Report 1-2

79-19 which described 22 inadequacies at STP. Based on the results of the investigation, the NRC's Office of Inspection and Enforcement issued .

a Notice of Violation and Notice of Proposed Imposition of Civil Penalties on April 30, 1980, accompanied by an Order to Show Cause why safety-related construction at STP should not be stopped 90 days from the date of the Order. Prior to the issuance of the Show Cause Order, HL&P had voluntarily stopped work on placement of complex concrete (December 28, 1979) and safety-related welding (April 11, 1980) in response to problems identified by the NRC as well as observations by HL&P and B&R QA/QC personnel. These Stop Work Orders were confirmed by Confirmatory Action Letters from NRC Region IV.

Extensive corrective actions were taken by HL&P to resolve the problems noted in the NRC's investigation and concurrent HL&P and B&R QA/QC audits. In January 1980, HL&P retained Bechtel Power Corporation to conduct an in-depth audit of the QA/QC program.at STP.

Other consultants were hired to review and advise management on soils, concrete, and welding, which were three areas where it was thought that deficiencies might exist. At the time of the 79 -19 investigation and report, these three areas represented the overwhelming majority of the then-completed safety-related construction work. HL&P devised extensive review programs to determine the adequacy of the work in each area and to prescribe and schedule any necessary repairs.

i (1) Soils HL&P and B&R initiated a soil test boring program in January 1980 to assess and verify the adequacy of the in-place Category I structural backfill at STP. This program was conducted by geotechnical engineers from Woodward-Clyde Consultants (WCC). This soils program verified the overall adequacy of the Category I backfill, but WCC recommended further confirmatory investigations in four specific locations. This program was completed in April 1980, 1-3

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After the issuance of the Show Cause Order on April 30, 1980, HL&P established a special Task Force to perform a second verification of previously-placed backfill. This Task Force consisted of geotechnical and QA engineers from B&R, HL&P, and WCC. In order to further guarantee the accuracy of its structural backfill analysis, the Project also hired Shannon and Wilson, Inc., to establish an independent Expert Review Committee of geotechnical experts to examine Category I structural back-fill at STP and to review the work of the special Task Force. Both the Task Force and the Expert Review Committee performed reviews of backfill placement at STP. In addition, the Expert Review Committee examined the methods used and analyses performed by the Task Force. Both the Task Force and the Expert Review Committee concluded .that in-place backfill at the Project met applicable Project and regulatory requirements. The NRC Staff, after reviewing the work of the Task Force and the Exoert Review Committee, concurred.

(2) Concrete A similarly extensive series of reviews were performed with respect to concrete placement. At the time the Order to Show Cause was issued, HL&P was already in the midst of a concrete verification and inspection program which covered 80 percent of the Reactor Containment Building shell walls and consisted of visual inspections, soundings, test borings, and core drillings. All significant voids discovered were mapped and filled.

Upon issuance of the Order to Show Cause, HL&P and B&R formed a Task Force to perform an assessment of the remaining safety-related concrete structures at STP. In addition, a special group of expert con-sultants was retained to ensure that the Task Force program was con-ducted properly.

The Task Force's review covered nearly 70 percent of all safety-related concrete placed at STP. Much of the remaining 30 percent was in

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structures, such as the Reactor Containment Building and the Essential Cooling Water Intake and Discharge Structure, which had already been subject to . review. Within each structure reviewed, a representative sample of concrete placements was selected for examination. The Task Force review proceeded in four phases: (1) a review of all documen-tation related to each selected concrete placement; (2) a field survey to verify that the "as-built" condition of the selected structures ,

corresponded to documentation; (3) a visual inspection of each place-ment; and (4) a random selection of three sample areas in etch placement ,

upon which to perform several specialized tests, including te t borings, i ultrasonic examination of consolidation, and verification of he loca-  ;

tion of embedded steel. At the end of this review, it was cs1cluded that the quality of safety-related concrete at STP was adequate an ' that

the performance of concrete structures would meet design requiremeits, j After examining the work of the Task Force and expert consultants, as ,

well as the results of a number of other tests, inspections, and repairs i performed on safety-related concrete at the STP, the NRC Staff agreed  ;

that no internal honeycomb or void areas remained unrepaired in the

! structures, i (3) Welding Safety-related welding at STP was also subjected to a thorough

! verification program. In response to Investigation Report 79-19, HL&P l and BLR formed a Task Force, similar to those for soils and concrete, to examine safety-related welding on the Project. An Independent Review Committee, consisting of three" experts, was retained to review and  ;

approve the work of the welding Task Forces  !

Initially, the welding Task Force examined randomly-selected safety-related piping and structural welds made by B&R. After this'in-itial investigation revealed a significant percentage of nonconforming welds, the Task Force recommended reexamination of safety-related welds 1-5 i

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and, where required, repair of these welds. Accessible safety-related structural (AWS Code) welds were reexamined and repaired as necessary to bring them into compliance with specifications. Furthermore, an evalu-ation of inaccessible structural welds demonstrated that each would per-form its intended function. Radiographs of ASME welds were reviewed according to a detailed examination and repair plan approved by the NRC Staff. All welds discovered to be defective during the course of the Task Force examination were repaired, and new procedures were put in place after the issuance of the Show Cause Order to ensure that welding deficiencies would not recur. The NRC Staff, which continuously moni-tored the efforts of the welding Task Force, concluded that HL&P had met its commitments relative to the safety-related welding program at STP and, therefore, in December 1981 closed out the welding item in the Show Cause Order.

1 In surrary, almost two years of effort were devoted to establishing the adequacy of safety-related construction at STP. The Atomic Safety and Licensing Board conducting the STP operating license proceeding, a after hearing the testimony of the Applicants, the experts who reviewed the work of the soils, concrete, and welding Task Forces, and the NRC Staff witnesses, and af ter examining all other aspects of the record related to the quality of construction at STP, stated: "We find that, as of the close of the Phase I record, there is reasonable assurance that the structures in place at the STP are in conformity with ap-plicable regulatory requirements." Houston Lighting & Power Company, et al. (South Texas Project Units 1 and 2), LBP-84-13, .19 NRC 659, 702 (1984).

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b. Reviews Related to the Transition of Responsibilities from Brown &

Root, Inc., to Bechtel Power Corporation and Ebasco Services Incorporated The termination of B&R and the subsequent takeover of the engi-neering and construction of S'TP by Bechtel and Ebasco, respectively, prompted review of all aspects of the engineering and construction at the Project. In both scope and level of detail, this review was un-precedented in the nuclear industry.

(1) Bechtel Power Corporation's Review of Engineering Under the terms of the contract between HL&P and Bechtel, Bechtel is obligated to assume design responsibility for all architect / engineer work on the Project, including work completed by B&R. Before Bechtel could accept responsibility for the adequacy of the existing design and resume design production, the precise status of all engineering and design work had to be ascertained. Therefore, upon being retained in the fall of 1981, Bechtel undertook an in-depth review of the entire STP design directed toward evaluating the adequacy of the existing design as well as determining what work remained to be done. With the assistance of engineering personnel from HL&P and B&R, Bechtel divided the engi-neering and design for STP into approximately 200 individual " work packages." Most work packages related to discrete physical structures or plant systems, such as particular buildings, piping, or mechanical  !

and electrical systems. Other work packages covered interdisciplinary  !

matters such as licensing documentation, pipe break analysis, and safe -

shutdown criteria. Again with the assistance of HL&P and B&R, Bechtel l assembled all of the latest revisions of the Project documentation per-tinent to each work package. The number and type of documents in each work package varied depending on its subject matter. Typical work )

packages might include system design descriptions, logic diagrams, flow diagrams, piping and instrument diagrams, equipment specifications, calculations, vendor drawings, isometric drawings, and o,t'her documents.

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Once a work package was assembled, Bechtel tr.oroughly examined all design documents in it. Depending on the nature of the work package, Bechtel evaluated the design assumptions and methods of analysis used by B&R, checked to see if applicable design criteria and technical require-ments were met, assessed the adequacy of design verification, reviewed design drawings and calculations for accuracy, and checked that the latest revisions of documents were being used by all disciplines. In its review of the work packages, Bechtel particularly considered find-ings of the Quadrex review 2 which related to the various work packages and collected the results of that review in a separate inter-disciplinary work package.

Bechtel generated a report on each work package and solicited com-ments as appropriate from cognizant engineers within B&R and HL&P. Each report included discussion of any technical problems identified by Bechtel, as well as a description of work necessary to complete the design. After meetings at which the comments on each work package report were reviewed, the work package reports were revised accordingly and transmitted to HL&P.

These work package reports remain part of the Project documentation and were the basis from which Bechtel resumed design production for STP in the spring and sucuner of 1982.

Bechtel's engineering review effort was overseen by the NRC. In February 1982, the NRC assigned a resident engineer to Bechtel's houston '

2The Quadrex Report was submitted to HL&P on May 7, 1981. It was com-missioned by HL&P to assess the status of B&R's engineering and its capability to complete the design in accordance with Project schedules.

Quadrex reviewers also examined selected design products and identified  ;

two items later determined to be reportable to the NRC under  ;

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offices to monitor on a full-time basis the transfer of engineering documents and Bechtel's review of these documents. The resident engineer performed reviews of selected work package reports, and engi-neers from the NRC's Office of Nuclear Reactor Regulation, assigned to aid the resident engineer, reviewed additional selected work package reports. This unusual degree of scrutiny of Bechtel's work by the NRC provides significant assurance that Bechtel's review of the STP design was systematic and thorough.

As a result of Bechtel's review, many changes were made to the STP design, and these were fully documented in Project records.

Although some constructed work had to be removed (for example, large amounts of Heating, Ventilating, and Air Conditioning (HVAC) duct work and cable tray supports), the extent of alteration of_ in-place com-ponents at STP was limited because, at the time Bechtel was retained in September of 1981, only about one-third of the construction at STP had been completed and only a small amount of equipment had been installed.

In addition, the majority of the work in place at that time had already been thoroughly inspected and, where defective, had been repaired or corrected as a result of the 79-19 investigation and related reviews.3 (2) Review of In-place Construction by Bechtel Power Corporation and Ebasco Services Incorporated Bechtel's takeover of architect / engineer and construction manage-ment functions also necessitated that STP be physically examined to determine the exact status of all construction at the Project.

Among the key aspects of Bechtel's review of plant construction was a series of "walkdowns" which collectively covered all completed i

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construction at the plant. During these walkdowns, the installed sec-tions of the plant were checked against applicable design drawings which, as the walkdowns progressed, were marked up to reflect the' extent to which construction of the items represented on the drawings had been completed. The walkdowns also assured that construction had proceeded according to the design or, alternatively, recorded the extent of any deviation from the design. Following each system walkdown, Bechtel audited the quality control records for completed construction on that system to . verify that these records had been properly generated and maintained. Thus, Bechtel's review not only provided for a physical check of completed work but also assured that documentation existed which provided objective evidence that work had been done properly.

In addition, Bechtel and Ebasco conducted special reviews of safety-related ASME welding at STP to verify that all such welds met Code standards. All accessible safety-related welds were visually inspected, and the documents and radiographs pertaining to these welds were examined to determine whether documentation for each weld was complete. Any welds found to be defective or to lack acceptable docu-mentation were repaired or radiographed to verify their adequacy.

The NRC monitored both the general transition of construction work and the special welding reviews. An NRC resident ir:spector was on the site full-time during this transition and reviewed various aspects of Bechtel's and Ebasco's transition activities. In addition, select teams of NRC personnel monitored the special welding reviews. The NRC's over-sight thus provided additional assurance that Bechtel and Ebasco per-formed their examination of in-place construction of STP in a thorough, consistent manner.

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B. THE LITIGATION BETWEEN THE OWNERS OF THE SOUTH TEXAS PROJECT AND BROWN & ROOT, INC.

1. Brief History of the Case HL&P and the other STP Owners filed suit against B&R and its parent corporation, Halliburton, Inc., (Halliburton) in December 1981, in the District Court of Matagorda County, Texas (the Court), some three months-af ter it was announced that B&R would be removed as architect / engineer and about six weeks after B&R announced that it would not' remain as constructor. The litigation continued for almost three and one-half years, during which the primary activities of the parties were discovery by means of depositions, interrogatories, and examination of documents and the preparation of reports by experts expected to testify in the litigation. In addition, the Court held a number of pre-trial hearings, most of which related to discovery and scheduling matters.

I,itigation activities ended in May 1985, when a tentative settle-ment was reached between all the parties to the litigation with the exception of the City of Austin. A final settlement was agreed to by ill parties in December 1985, and the lawsuit was accordingly 4

dismissed . One ramification of the settlement should be noted. During the pendency of the lawsuit, the Court had imposed a protective order preventing the parties from making available to the public information learned during the discovery process. When the parties arrived- at a settlement, the Court ordered this protective order dissolved. Thus, with the exception of Bechtel's responses to written deposition questions posed by Brown & Root, all of the interrogatory answers, depo-sition transcripts and exhibits, and expert reports filed in the case  ;

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4 The City of Austin filed a separate lawsuit against HL&P in 1983; that suit is pending in Travis County, Texas.

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have become publicly available. Bechtel's responses were under a separate protective order which remains in effect, but have nonetheless been reviewed in the Litigation Record Review Program.

2. Issues in the Litigation The primary issues in the litigation related to B&R's performance on the Project from 1972 until September 1981. The plaintiffs' central theory was that B&R had breached its obligation to the STP Owners by failing to perform the architect / engineering and construction for the Project in the manner contemplated by the contract. B&R had completed

, less than 50 percent of the engineering and about one-third of the construction for both units at the date of its termination. The plain-tiffs particularly focused on B&R's inability to complete the engi-neering and design of the Project and on certain inadequacies in those portions of B&R's design that had been completed. By and large, the performance of B&R as constructor at the STP was acceptable; the Owners had, in fact, desired to retain B&R as constructor. They were unable to do so because of B&R's refusal to continue on the job without major modifications to its contract.

In defense of its performance, B&R contended that it had performed as well at STP as other architect / engineers and construction managers had at other facilities being built during the same time period. B&R cortended that regulatory circumstances, vendor problems, the actjons of HL&P as Project Manager, and other factors prevented it from achieving Project schedules.

Many issues in the case were unrelated to plant safety or oper-ability. For example, the Owners claimed that B&R incorrectly stated the amount of engineering completed at various points in time. While relevant to B&R's performance of its obligations to the Owners, this question is not germanc to whether the plant was properly engineered and constructed. Among the other issues unrelated to plant safety were the 1-12 i

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l nature of the corporate relationship between B&R and Halliburton, B&R's scheduling techniques, the amount of damages suffered by the Owners, the costs of comparable plants, and the history of the negotiations of the contract between HL&P and B&R,

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The allegations regarding deficiencies in B&R's performance were, of course, developed by HL&P and the other plaintiffs. They are identi- I fled with particularity in the plaintiffs' " Specification of Claims and j Issues." B&R's position is contained in its " Specification of Claims l and Defenses." Both documents were transmitted by HL&P to the NRC and 1 persons on the service list in the STP operating license proceeding by I letter of April 22, 1985.

3. The Parties' Major Activities in the Litigation

a. Discovery The parties on both sides of the litigation spent most of their energies conducting discovery to establish the facts relevant to the case. This discovery was conducted primarily by means of interroga-tories, depositions, and requests for production of documents.

(1) Interrogatories Interrogatories are written questions propounded by one party to an opposing party or parties in a lawsuit. Parties to whom interrogatories are propounded are required to answer them unless they call for legally privileged information or are otherwise objectionable. All parties to -

the STP litigation made extensive use of interrogatories to extract information from opposing parties. By the time the litigation was settled in May 1985, most of these interrogatories had been answered.

1 Many of the interrogatories addressed to the various parties con- )

cerned technical issues that could possibly relate to the safety of design or construction at STP. Particularly noteworthy ~ in this regard 1-13 i

I were interrogatories prepared by B&R which required HL&P to list for each Bechtel work package all of the technical deficiencies found in the B&R engineering work included in the work packags. However, more than half of the interrogatories and answers related only to issues having no bearing on plant safety, such as cost, scheduling, the parties' cor-porate relationships, and damages.

(2) Depositions Depositions were used extensively to discover information related to issues in the litigation. B&R, Halliburton, and the plaintiffs took deposition testimony from more than 270 witnesses during the course of '

discovery, covering all of the major issues in the case. Documentary -

exhibits were used as a basis for much of the questioning, and these exhibits were filed in the Court with the transcripts of the oral depo-sitions.

Of the hundreds of depositions taken by the parties during the litigation, only a portion contained questions or testimony related to plant safety. As with interrogatory answers, much of the deposition testimony concerned issues that did not relate to plant safety such as cost, schedule, corporate relationships, and damages. Many of the wit-nesses who gave testimony were not involved with any of the design or construction work for the plant and did not have the background to understand technical issues related to such matters.

(3) Requests for Production o' Documents A third means of discovery employed by the parties was the request for production of documents. By serving a request for production of documents, one party could compel another to produce for inspection and copying all documents fitting a certain description or relating to a particular topic. Usually, the parties requesting the documents would not copy all documents produced but would screen the documents to select those to be copied.

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Extensive use of documents received in resoonse to requests for production was made in depositions taken by the parties. In preparing for depositions, the attorneys on both sides of the litigation, often in consultation with knowledgeable engineers, would gather documents related to issues to be addressed in the deposition; these.were often incorporated as deposition exhibits.

b. Experts and Expert Reports In preparation of their case for trial, the parties to the STP litigation retained experts to testify at trial on various issues in the lawsuit. These experts made detailed inquiries into the issues that were to be the subject of their eventual testimony had the case gone to trial. Experts who the parties planned to have testify in the lawsuit were required to prepare reports sumarizing their findings on the I issues upon which they were to testify so that the opposing parties would have the opportunity to prepare their case on those issues.

Of the reports prepared by these experts, the one most relevant to the technical adequacy of STP engineering and construction is the Report on Brown & Root Engineering on the South Texas Project, prepared -by S. Levy Incorporated (SLI). and issued on October 1, 1984. This report was the culmination of an extensive and detailed review of B&R engi-neering documents, engineering-related correspondence, Bechtel work packages, deposition transcripts, and some Bechtel design documents and was carried out by highly trained engineers experienced in the nuclear field. The SLI review covered a majority of the safety-related systems engineered by B&R and evaluated the STP design as of the time B&R was terminated as architect / engineer. In addipion, during the time it was preparing its report, SLI reviewed all but a few of the remaining Bechtel work packages in assisting HL&P to prepare responses to inter-rogatories posed by B&R. The SLI engineers were aware of their reporting obligations under NRC regulations; SLI notified the Project of misp

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three items, all of which were found to have been resolved.

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In its Report, SLI presented its findings as to B&R's performance as architect / engineer for STP and the adequacy of its design for the Project as of September 1981. The Report included descriptions of the deficiencies found by SLI in the course of its review. However, SLI also noted in its Report that "SLI has not independently identified any deficiency reportable under NRC regulations, and has not identified any deficiency, reportable or non-reportable, not currently being addressed by Bechtel." The Report was reviewed by STP Licensing and Engineering personnel to determine whether it reflected any safety deficiencies reportable under 10 CFR 50.55(e) which had not been previously reported to the NRC. The review disclosed no such deficiencies.

Other expert reports, related to more limited areas of STP design and engineering, include reports by plaintiffs' consultants James R.

Wells (on concrete work at STP) and J. C. Lavallee (on Nuclear Steam Supply System (NSSS) and architect / engineer interface).and two reports by Cygna (a B&R consultant) on QA. As with SLI, the work of these con-sultants was directed toward evaluating work performed prior to September 1981. None of these reports revealed any deficiency not remedied by B&R, Bechtel, Ebasco, or HL&P. Finally, a number of expert reports do not pertain at all to the safety of STP design or construc-tion, but to issues such as Project cost and schedule, accounting, and Halliburton control of B&R.

c. Litigation Interface with the Project During the course of the litigation, the lawyers and experts pre-paring the plaintiffs' case were assisted by HL&P engineers familiar with various aspects of Project design. These engineers helped ensure that the lawyers and experts understood the significance of the dif-ferent STP design documents, and they assisted in obtaining complete documentation for experts working on technical issues. In March 1984, 1-16 e

HL&P created a formal Project Interface Team consisting of engineers knowledgeable about the STP design. The Project Interface Team reviewed many of the more significant technical interrogatory answers for accuracy including drafts of answers to the most detailed and compre-hensive set of technical interrogatories filed in the lawsuit (HL&P's responses to B&R's Ninth Set of Interrogatories). The Team also reviewed several of the deposition transcripts on technical subjects to determine which portions of these transcripts contained significant information. These engineers, most of whom had been involved with Project engineering or QA, understood their obligations to notify the Project of any deficiencies in STP design or construction brought to light by the litigation that were not already being addressed by  ;

Bechtel, Ebasco, or HL&P. The involvement of these engineers in the litigation effort not only assured technical accuracy in the plaintiffs' preparation of their case, but provided added assurance that any hitherto undiscovered deficiencies brought out in preparing for the litigation would be identified to the Project and resolved. No such deficiencies were identified.

C. HOUSTON LIGHTING & POWER COMPANY'S UNDERTAKING TO REVIEW' RELEVANT PARTS OF THE LITIGATION RECORD In 1985, it was determined that the record of the litigation should be examined to determine whether it contains information regarding any safety-related deficiencies in the STP design or construction which had not previously been identified, and HL&P undertook a systematic review for this purpose.

A proposed review program was discussed in meetings with the NRC Staff on July 31 and August 28, 1985, and the Staff's oral comments were

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reflected in the program submitted 'to the NRC by letter dated August 30, 1985. By letter dated October 29, 1985, the NRC (Region IV) furnished written comments on the program to which HL&P responded by letter dated 1-17

November 26. In essence, the NR'C's comments sought clarification of the scope of the Litigation Record Review -Program and of the criteria established for identifying an " assertion" and for determining whether ,

an assertion is " safety-related." HL&P's letter of November 26, 1985, responded satisfactorily to the comments, and no modifications to the program were required.

The review began in September 1985 and has required approximately 30,000 man-hours of engineering effort by the contractor, S. Levy Incorporated. This document reports the results.of the review. '

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SECTION 1 REFERENCES  !

1-1 Letter from J. H. Goldberg, Group Vice President, Nuclear (HL&P) to Robert 0. Martin, Regional Administrator, Region IV (NRC),

dated August 30, 1985,

Subject:

Review of the HL&P v. B&R Litigation Record 1-2 Engineering and Construction Contract Between HL&P and B&R for STP, dated October 31, 1972 1-3 Houston Lighting & Power Co. v. Brown & Root, Inc., Original Petition for Damages and Application for Declaratory and Equitable Relief, filed December 28, 1981 1-4 Letter from G. W. Oprea, Jr., Group Vice President (HL&P) to 4

J. F. O' Leary, Director of Licensing (AEC), dated May 14, 1974,

Subject:

South Texas Project Units 1 and 2 Application for Construction Permits and Operating Licenses 1-5 Memo from D. G. Barker to J. H. Goldberg, dated October 13, 1981,

Subject:

Transmitting Minutes of Bechtel/B&R/HL&P Transition Meeting No. 1, October 1, 1981 1-6 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Report No. 50-498/79-19; 50-499/79-19, transmitted Apri l 30, 1980,

Subject:

Investigation of South Texas Project, Units 1 and 2 1-7 In the Matter of Houston Lighting & Power Co., Order To Show Cause (Effective Imediately), dated April 30, 1980 1-8 Houston Lighting & Power Company, et al. (South Texas Project, Units 1 and 2), LBP-84-13, 19 NRC 659 (1984) (Phase I Partial Initial Decision), dated May 14, 1984 i

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1-9 Letter from B. L. Lex, Project Manager (Bechtel) to D. G. Barker, Manager, South Texas Projects (HL&P), dated April 22, 1982,

Subject:

South Texas Project, Bechtel Job. No. 14926-001, Plan for Change of Responsibility for ASME Section III Reactor Coolant Loop Piping 1-10 Letter from G. L. Madsen, Chief, Reactor Projects Branch (NRC) to G. W. Oprea, Jr., Executive Vice President (HL&P), dated October 5, 1981,

Subject:

U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Report No. 50-498/81-25; 50-499/81-25 1-11 Houston Lighting & Power Co. v. Brown & Root, Inc., Agreed Protective Order, dated September 22, 1983 1-12 Houston Lighting & Power Co. v. Brown & Root, Inc., Order to Vacate Protective Order, dated May 30, 1985 1-13 City of Austin v. Houston Lighting & Power Co., Plaintiff's Original Petition, dated January 6, 1983 1-14 Memo D. G. Barker to J. H. Goldberg, dated October 9, 1981,

Subject:

Transmitting Minutes of Bechtel/B&R/HL&P Transition Meeting No. 2, October 7, 1981 1-15 Letter from J. H. Goldberg, Group Vice-President, Nuclear (HL&P) to Robert D. Martin, Regional Administrator, Region IV (NRC),

dated April 22, 1985,

Subject:

Transmitting " Specification of Brown & Root's Claim and Defenses Pursuant to the Court's Order of November 1, 1984" 1-16 Letter from Robert D. Martin, Regional Administrator, Region IV j (NRC) to J. H. Goldberg, Group - Vice President, Nuclear (HL&P),

dated October 29, 1985,

Subject:

Review of the HL&P v. B&R Litigation Record: HL&P File No. G25.G4.2 1-20 l

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1-17 Letter from J. H. Goldberg, Group Vice President Naclear (HL&P) to Robert D. Martin, Regional Administrator, Region IV (NRC),

dated November 26, 1985,

Subject:

Response to NRC Comments on the HL&P B&R Litigation Record Review 1

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Section.2 PURPOSE OF THE LITIGATION RECORD REVIEW PROGRAM The purpose of the STP Litigation Record Review Program was to determine whether the litigation record discloses any previously un-identified safety-related deficiencies in STP systems, structures, or components (SSC) or their associated design or quality documents. This review was not intended to duplicate previous extensive reviews of STP design and construction performed by HL&P, Bechtel, Ebasco, and other contractors, but to determine whether there is any new - information embodied in documents generated for the litigation that reveals some safety-related deficiency which has not already been resolved or identi-fied for resolution by the Project. The Litigation Record Review 4

Program was designed to produce a complete and retrievable record of its performance and results.

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Section 3 SCOPE OF THE LITIGATION RECORD REVIEW PROGRAM A. THE LITIGATION RECORD The litigation record in HL&P v. B&R consists of several types of documents which have widely differing levels of relevance to the tech-nical aspects of STP design and construction. Each type is described below. Information regarding the nature of the litigation record was drawn frcm Reference 1-1 listed at the end of Section 1. S. Levy Incorporated has performed no independent investigation into the general history of STP or the STP litigation.

1. Complaints, Counterclaims, and Answers Perhaps the most basic documents in the litigation record are the plaint'iffs' complaints and the defendants' counterclaims and answers.1 These documents contain general, broad-brush descriptions of the various claims and defenses made by the parties to the litigation. They are probably best viewed as an index or broad sumary of the parties' legal and f actual positions. The complaints, counterclaims, and ' answers may contain some information regarding asserted deficiencies in.STP systems, structures, and components '(SSC); but they do not lend themselves to meaningful technical review because they lack technical -detail.

Furthermore, any claims made in the complaints, counterclaims, and answers are reiterated in far more detail in interrogatory answers, deposition transcripts, and expert reports filed by the parties.

l Each of these documents underwent several revisions.

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2. Motions A second group of documents in the record consists of the various motions and responses to these motions filed by the parties. These motions deal with such matters as scheduling discovery, setting a trial date, regulating the scope of the lawsuit, and compelling parties to produce documents or to answer interrogatories. In general,'they relate to the legal theories and positions of the parties and not to the facts underlying the lawsuit. They do not contain testimony and were not filed for the purpose of providing information about facts related to issues in the lawsuit. In those rare instances where such facts are provided, the motion or response almost invariably references a deposi-tion transcript, interrogatory answer, or expert report as the source of these facts.

3. Court Hearing Transcripts During the course of the litigation, the Court held a number of hearings to consider motions filed by the parties and matters related to readying the case for trial. Most hearings were open to the public.

These hearings typically concerned such matters as the schedule for discovery, setting of a trial date, narrowing the issues in contention,

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and compelling parties to produce documents, answer interrogatories, or produce 'sitnesses. Because the case was settled prior to trial, the Court trade no findings except that the Court found the settlement of the lawsuic satisf actory.

4. Interrogatory Answers and Responses to Requests for Admissions Interrogatories and requests for admissions were used by all par-ties to the STP litigation to discover the facts behind the various claims and defenses made by the parties. The answers to these interrog-atories usually provide factual information, although at varying levels of detail.

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Many interrogatories and requests for admissions sought no infor-mation related to the design or construction of STP; accordingly, the answers are not relevant to this review. Other interrogatories, however, sought information on STP design or construction, and the answers therefore provided such information, often in considerable detail.

5. Deposition Transcripts Transcripts of the deposition testimony of a large. number of wit-nesses were made and filed with the Court. Many of the persons deposed, because of their position (such as accountant, financici executive, attorney), had no knowledge of the technical aspects of the STP design or construction. Other depositions are not of interest because the STP design and construction were outside their scope. However, the testi-many of some deponents, most notably those of engineering personnel who had worked on the STP, contains substantial relevant information on design and construction.

6. Expert Reports Experts expected to testify on various subjects in the litigation prepared reports describing their findings on the issues that were to be the subject of their testimony. Many expert reports-dealt with issues, such as plant cost and schedule, financial constraints, personnel turn-over, and Halliburton control of B&R, which had no t, earing on the tech-nical adequacy of STP design and construction. A few of the expert reports, especially the report on B&R engineering prepared by S. Levy

• Incorporated, are focused on various technical aspects of STP design and construction.

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7. Requests for Production of Documents Parties to the STP litigation filed requests for production of documents to compel opposing parties to produce documents on various issues for inspection and copying. Usually, a formal response to a request for production of documents would be filed with the Court. This formal response would include any objections to the request and would state the extent to which the party would comply with the request.

However, the actual documents requested were not filed with the Court but were simply made available to the party that requested them for inspection and copying. The requests for production and the formal responses thereto contained no assertions related to the adequacy of. STP design or construction.

B. SCOPE OF THE LITIGATION RECORD REVIEW PROGRAM The Litigation Record Review Program covered all litigation record documents in the following categories that were in the custody of the Court: (1) interrogatory answers, (2) deposition transcripts,2 and (3) expert reports. Approximately 100,000 pages of these documents were reviewed on a line-by-lir.e basis. These categories contain the docu-ments created during the course of the litigation which convey substan-tive factual information and which are therefore the documents most likely to contain new information or insights, if any, with respect to potential safety-related deficiencies in STP systems, structures, or components.

For the reasons discussed above, neither the complaints nor - the counterclaims, answers, or motions were examined; to the extent they 2B ecause the litigation was settled prior to trial, some documents that ordinarily would have been filed with the Court, including certain depo-sition transcripts, had not yet been signed or filed with the Court. l However,.such documents were treated for purposes of this review as having been in the custody of the, Court and were reviewed.

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relate to design or construction issues, the relevant details are disclosed in the interrogatory answers, depositions, and expert reports which were reviewed.3 The transcripts of Court hearings deal with the mechanics of the discovery process, rather than substantive technical matters; accordingly, they were not examined. Neither the requests for production of documents nor the responses contain factual information themselves. Documents furnished in response to such requests (with the exception of expert work papers) were not prepared for the purpose of the litigation and, therefore, generally were not examined. These docu-ments were either already part of Project records or are of a type not normally examined by the NRC for licensing purposes. In any case, to the extent these documents relate to technical aspects of STP engi-neering or construction, they were generated by personnel obligated under Project procedures and NRC regulations to report any safety-related deficiencies.4 Many such documents formed the basis for questions posed in depositions and became exhibits to those depositions.

If the pertinent deposition was reviewed, any related exhibits were also examined to the extent necessary to understand the deposition. With respect t ' expert reports, although the expert's work papers were not reviewed, '1e salient information contained in them is reflected in the reports themselves which were reviewed.

3 HL&P prepared an index to the complaints, counterclaims, and answers to assist the NRC and other reviewers in understanding the relationship of the materials to be reviewed to the issues in the litigation. This index was provided to the NRC Staff on December 2, 1985.

4 STP QA was examined in detail during_ Phase I of the STP operating license proceedings in 1981 and 1982. At the end of those proceedings, the licensing board concluded that "HL&P is presently managing, planning and implementing its program for the balance of design and construction for STP, including its-QA program, in a manner which provides reasonable assurance that future design and construction work at STP will be in conformity with the construction permits, the Atomic Energy Act, as amended, and the Rules and Regulations of the Commission." Houston Lighting & Power Company, et al. (South Texas Project Units 1 and 2),

LBP-84-13,19 NRC 659 (1984).

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Section 4 METHODOLOGY AND PERFORMANCE 1

0F THE LITIGATION RECORD REVIEW PROGRAM The litigation record was reviewed in two stages. First, the interrogatories, deposition transcripts, and expert reports were screened to. identify those likely to contain technical information on the STP design, construction, or QA/QC. Second, those documents not eliminated during screening were reviewed line-by-line to identify any assertions of deficiencies in STP systems, structures, or compnnents (SSC) or their associated de:!gn or quality documents. Each statement determined to be an assertion was further examined to determine:

1) whether the assertion is safety-related--that is, whether the asserted deficiency involves a safety-related SSC; or

2) if the assertion is determined to be safety-related, whether the Project has already resolved the matter covered by the assertion or identified it for resolution; or

3) whether the assertion is factually erroneous.

If the assertion was determined to be safety-related, but -had not been rcsolved or identified for resolution by the Project and could not be shown to be factually erroneous, I litigation review Procedures required preparation of an STP Deficiency Evaluation Form (DEF) covering the substance of the assertion and transmittal of the DEF to HL&P's STP Engineering for consideration in accordance with th'e applicable-Project l Procedure (PLP-02) pursuant to 10 CFR 50.55(e). (A flow chart showing -

-the overall review process appears in Attachment 4-A.) i i

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A. THE SCREENING PROCESS

1. Purpose of Screening Interrogatories, deposition transcripts, and expert reports were screened to Ensure that all such documents which might contain infor-mation related to technical aspects of the design or construction of STP SSC would receive detailed, line-by-line reviews.

2. Criteria and Methodology of the Screening Process The screening began on August 27, 1985, and was performed by three HL&P cngineers and two attorneys. These individual's worksd in two-person teams, eac'1 consisting of an attorney and an engineer familiar with the design of STP and with issues in the litigation. Using written criteria, the screening teams examined the depositions, expert reports, and interrogatories filed in the litigation to determine which of these documents would be included for detailed review by SLI. For each docu-ment which a screening team determined did not require review, a short statement was prepared explaining why the document should not be reviewed. The sheet upon which this statement appeared was signed by both members of the screening team. When there was any reasonable doubt as to whether a document should be included for detailed review, it remained on the list of documents to be reviewed. The criteria used for.

identification of documents for detailed review are set out in Attachments 4-B (interrogatories), 4-C (depositions), 'and 4-D (expert reports); they may be sumarized as follows:

a. Interrogatories The responses to. any interrogatory requesting information on - the following subjects was included for detailed review: engineering for STP, construction work at the STP, QA/QC activities or programs for the STP, and reviews or reports on engineering or construction for STP.

A-2

1 Interrogatories requesting information only about other specified sub-jects, unrelated to technical aspects of the construction or engineering of STP, could be excluded. Those subjects were Halliburton control over B&R; accounting, economics, and the financial ability of the Owners to complete STP; B&R personnel qualifications (except as related -to specific construction or engineering deficiencies), turnover, and staffing levels; Project schedule and percentage of work completed; Allen's Creek Nuclear Generating Station; B&R's history and experience as architect / engineer outside its performance on STP; the Owners' experience in design and construction of facilities other than STP; and B&R's and Halliburton's affiliation with subsidiaries. (See Attachment 4-B.)

b. Deposition Transcripts Depositions of witnesses who held or had held engineering, construction, QA/QC, or licensing positions on STP were required to be included. Depositions of witnesses falling into other listed cate-gories, such as accountants, NRC employees, financial witnesses and public officials, could be excluded. Depositions limited to a specified subject could be excluded from review if the subject was one of the following: Halliburton control over B&R; accounting; financial constraints on completion; B&R personnel qualifications (except as related to specific construction or engineering deficiencies), turnover, and staffing levels; Project control; terms of the contract between the STP Owners and B&R; B&R's and Halliburton's affiliation with NUS; admin-istrative matters and cost estimates; the D0J v.- Halliburton antitrust suit; public relations; and site access for construction. A deposition coula not be excluded if its subject concerned any STP SSC; QA/QC activ-ities or documentation related to any STP SSC; or reports or reviews concerning the quality of STP engineering, construction, or QA/QC of any STP SSC. (See Attachment ~4-C.)

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c. Expert Reports All expert reports containing information on engineering or construction of the STP or-the substance of QA/QC findings were included for review. Reports containing only information on a list of specified subjects (such as Halliburton'~s relationship with B&R, general nuclear industry information not specifically related to STP, etc.) were excluded. (See Attachment 4-D.)

3. Checking the Results of the Screening Process As the initial screening work moved toward completion, checking of-the screening results began. Checking was performed by an attorney /

engineer team other than the team which performed the initial screening. Using the screening criteria described above, these checking teams re-examined each instance in which an-interrogatory, deposition, or expert report had been excluded from detailed review to ensure that no documents had been incorrectly excluded. The checking teams made notations indicating the results of the checking process on the original sheets which documented screening process results or on separate sheets appended to the original sheets. Checking team members signed all screening process results sheets examined, as well as any appended sheets.

Although this checking resulted in minor changes in the list of items included for detailed review, it essentially confirmed the results of the initial screening. The checking teams determined that a rela-tively small number of interrogatories which~ had been excluded from detailed review should be included, either because the engineer and attorney performing the checking disagreed with the initial-decision to exclude or for reasons of administrative convenience.1 The checking 15 ee footnote on p. 7-2.

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process did not result in any changes in the determ nations made in the initial screening of depositions or expert reports Both the initial screening and the checking were completed by September 30, 1985.

The documents recording the results of the initial screening and checking were organized into files and are stored at HL&P's offices in Houston, Texas. The list of documents identified during the screening process for review by SLI is presented in Appendix A.

B. DETAILED REVIEW 0F SELECTED LITIGATION DOCUMENTS

1. Introduction Those parts of the litigation record identified for detailed review during the screening process were reviewed in their entirety by S. Levy

Incorporated (SLI) to determine whether they disclosed any previously unidentified safety-related deficiencies in the design or construction of STP systems, structures, or components (SSC). For purposes of the review, a " deficiency" was defined as a defect that will or may impair the ability of an SSC to perform its intended function. Statements which did not identify a specific deficiency in an SSC were nevertheless designated assertions if they pertained to documents which provide objective evidence of the quality of design or construction for a speci-fic SSC (for example, the absence of calculations for system X, lack of verification documents for calculation Y, incomplete QC records for weld N). A set of the Procedures governing SLI's performance of the litigation review is contained in Appendix C.

Preliminary planning for the detailed review began in early August 1985. Estimates were made of the volume and characteristics of the materials to be reviewed. These estimates, in cc,mbination with established schedule requirements, were used to project the manning levels required as well as the appropriate mix of personnel skills, edu-cation, and experience. Mobilization of the required personnel began in mid-August.

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2. The Litigation Review Team The detailed review of the litigation record was conducted by a team which included a Team Leader, Reviewers, Discipline Specialists, and Overview Specialists. More than 50 engineers participated in the work. SLI also employed a staff of administrative and clerical person-nel to provide support for the technical participants in the review.

a. Technical Participants in the Detailed Review The Litigation Review Team consisted of employees.or subcontractors of S. Levy Incorporated (SLI). Individuals who had participated in the preparation of SLI's Report on Brown & Root Engineering on the South Texas Project and of technical interrogatory answers during the HL&P v. B&R litigation were utilized to the maximum extent, thereby pro-viding a cadre of individuals already familiar with the design and construction of the STP and associated technical issues.

Reviewers reviewed the litigation record documents included for review during the screening process to identify and record any asser-tions of deficiency appearing in those documents. Reviewers were engi-neers with at least three years of engineering experience in their respective disciplines.

The Discipline Specialists examined the statements recorded by Reviewers to determine whether these statements failed to meet the cri-teria for identification of assertions of deficiency, were not safety-related, had already been identified in Project documentation, or were factually erroneous. Discipline Specialists ' vere engineers with at least seven years of experience working in their respective disciplines on nuclear power plant engineering, design, or construction.

The Overview Specialists reexamined each instance in which a Discipline Specialist had determined that a statement did not meet the 4-6

e criteria for identification of an assertion. The Overview Specialists also examined each instance in which a Discipline Specialist had deter-mined an assertion to be not safety-related to ensure that this deter-mination was correct in light of any possible systems interaction or interdisciplinary effects. Overview Specialists had at least ten years of experience doing multi-disciplinary engineering work or overseeing engineering work in different disciplines on nuclear power plants.

The Team Leader was responsible for overall management of the Litigation Record Review Program. The Team Leader (and those - he designated to perform tasks assigned to the Team Leader) had a minimum of ten years of technical management experience related to nuclear plant engineering, design, or construction.

The actual qualifications of the technical participants in the review process considerably exceeded the minimum qualifications stipu-lated. The names and levels of experience of technical- participants in I the Litigation Record Review Program are listed in Appendix B.

Depending on their qualifications, some individuals performed more than one review function. (For example, some individuals qualified to the level of Overview Specialists acted as Reviewers, Discipline  ;

Specialists, and Overview Specialists.) i A resident engineer from HL&P's Nuclear Licensing department moni-tored the work of the Litigation Review Team and, in conjunction with HL&P engineers in Houston, aided in obtaining necessary information and l

.1 documents from the Project. I

b. Training of Technical Participants for the Review l Before undertaking any detailed review work, each member of- the Litigation Review Team attended a formal orientation and training session. The first formal training session was held on September 6, 1985. The session opened with orientation presentations by Mr. Jerome 4-7

Goldberg, Group Vice President--Nuclear of HL&P; Dr. Salomon Levy, President of SLl; Mr. C. B. Johnson, 'the Review Team Leader; and HL&P's counsel. In subsequent training sessions, these presentations were reproduced from video tapes. The bulk of each session was devoted t to detailed presentation and discussion of the Plan, Procedures, and Guidelines, with emphasis'on the criteria to be used. These documents and any subsequent revisions were issued to each participant. The Plan contains requirements for administrative action by SLI such as schedule and distribution lists. The Procedures (see Appendix C) .contain the ,

technical requirements of the review. The Guidelines contain'explana-tory--information and examples aimed at assisting the participants.- The

, Guidelines are subordinate to the Procedures. Each session was -

augmented by a general presentation of tue meaning and intent of-10 CFR 50.55(e) and how it is implemented by HL&P. This presentation 4 l

was made by Mr. Michael Powell, Supervising Engineer--STP Licensing for l HL&P. The SLI Corporate Quality Assurance Manager presented SLI's method. ology for implementing 10 CFR 50.55(e) and Part 21, and the obli-gations of each participant under these regulations. This and later sessions occupied approximately six and one-half hours of actual time.in class.

[

3 Class size was limited to approximately ten or less . to promote  :

discussion; accordingly, there were several training sessions.

4 In addi- i tion, all of the ' Quality ' Assurance personnel for SLI and HL&P par- t ticipated in a training session, and many of the support-personnel from the SLI Computations and Records Centers participated for the purpose of general orientation. A representative of the NRC ' Region IV Staff  ;

attended one session. ,

4 1

In addition to the orientation and training session, each technical member of the Litigation Review Team received a training manual con-taining controlled copies of the Plan, Procedures and Guidelines, and l general STP information . These were kept - up-to-date by inserting 4-8 '

I T*r -

y w v- q -p- qe; .maa p- , y g - - . , im, .-g .i - - - -- ++g-r-e9w -p--- ye

current revisions to the Plan, Procedures and Guidelines as they were issued. Technical members of the Litigation Review Team referred .to ,

their training manuals for guidance during the course of their review work.

c. S. Levy Incorporated Computations and Records Centers To support the technical staff, SLI established a Computations Center and a Records Center. The Computations Center utilized SLI's data base system of hardware and software that permitted the information prepared by Litigation Review Team members to be recorded and stored in a controlled, uniform, and accessible fashion. The Records Center is the repository for hard copies of documents used in the review, including copies of litigation record documents reviewed, Project docu-ments used in the review, and the various forms and other documents pre .

pared during the review by the Litigation Review Team.

3. Steps in the Detailed Review Process The Litigation Review Procedures governing the work of Reviewers, Discipline Specialists, and Overview Specialists are schematically represented in the Flow Chart appearing in Attachment 4-X.

a. Line-by-Line Review of Record D0cuments Identified During the Screening Process A complete list of all depositions, expert reports, and interroga-tory answers 2 to be reviewed was prepared, based on the results of the I

2With respect to interrogatories, it should be noted that SLI reviewed the answers to interrogatories. These answers were filed in sets- l corresponding to the sets of interrogatories. In some cases, more than j one response was filed to an interrogatory and, in a few cases, no '

response was filed. SLI reviewed all responses filed to interrogatories included for review during the screening process. In those instances where no response was filed, there was no material for SLI to review.

4-9

. i

screening. (See Appendix A.) The Team Leader assigned specific materials from this list to individual Reviewers according to the sub-ject matter of the material and the Reviewer's education and experience.

Reviewers began their review of record documents on September 7, 1985.

Each Reviewer read every line of his assigned review material. To help assure thorough and focrsed review of every line of every document, each Reviewer made notations in the margin as to the subject matter of the material he was reading and the location of any assertion appearing in it. For each assertion of deficiency in the design or construction of an STP SSC (or associated QA/QC documentation) contained in the review material, the Reviewer completed an Assertion Form, including the exact location of the assertion of deficiency in the reviewed document and a description of the assertion. The Reviewer also assigned the assertion one or more category designators denoting the technical area to which the assertion pertained (e.g., Mechanical, Electrical, Structural). The criteria used by the Reviewers to identify assertions of deficiency are specified in Attachment 4-E. Reviewers were instructed to assume that statements made in litig~ation record documents were true and accurate and to record as assertions even those statements which appeared to fall only marginally within the established criteria.

All assertions of deficiency were recorded regardless of whether or not they appeared to be safety-related. The Reviewer also recorded the location of every substantive reference to NRC competence or performance on an NRC Citings Form.

After completing his review of a particular record document, the Reviewer submitted the handwritten Assertion Forms and NRC Citings Forms for that document to the SLI Computations Center for entry _into the com-puterized data base. SLI Computations subsequently supplied the Reviewer with computer printouts of each form. The Reviewer checked these printouts for accuracy and signed them; the signed printouts constitute the official Assertion Forms. Examples, of completed 4-10 t - -

Assertion Forms appear in Attachment 4-J on pp. 4-J-1, 4-J-4, 4-J-7, 4-J-10, 4-J-12 and 4-J-14. These signed Assertion Forms were filed in the Records Center. Any subsequent changes to the Assertion Form were made by formal revision; all versions are retained in the Records Center. Listings of substantive references to the NRC in record docu-ments have been provided to HL&P for transmittal to the NRC.

Review cf record documents for identification of assertions of deficiency was substantially completed on November 30, 1985.

b. Disposition of Assertions of Deficiency The completed Assertion Forms prepared by the Reviewers were >

collected and sorted by the Team Leader and his designees according to discipline. The Team Leader and his designees also grouped those asser-tions that appeared to be susceptible to the same disposition so that they could be examined together. The assertions were then assigned to one of four Disposition Squads. Each Disposition Squad consisted of a Squad Leader and several Discipline Specialists and covered a number of '

technical areas. Within each squad, the Squad Leader assigned asser-tions to individual Discipline Specialists. The Squad Leaders also grouped similar assertions recorded from different litigation record documents so that they could be examined by the same Discipline ,

Specialist.

The Discipline Specialists examined the Assertion Forms assigned to them to determine whether they could be disposed of in one of four ways:

1) In cases where it appeared that a statement was recorded that in fact failed to meet the criteria defining an assertion of -

deficiency (see Attachment 4-E), the statement was re-examined along with the text of the litigation record document from which it was taken. Statements found not to meet the criteria were not reviewed further by the Discipline Specialists.

1 4-11

-n -- +m,- , - - . . - . ,. - , , .

(See, by way of example, the sample Disposition Form on p.

4-J-2.) However, as a double-check, these statements were further evaluated by Overview Specialists. (See pp. 4-14 and 4-15.)

2) The Discipline Specialist could determine that the substance of the assertion was not safety-related. The _ specific cri-teria used by the Discipline Specialists in this determination are listed in Attachment 4-F. Assertions of deficiency deter-mined not to be safety-related were not reviewed further by the Discipline Specialists. (See, by way of example, the sample Disposition Forms on pp. 4-J-5 and 4-J-8. ) However, these assertions were further evaluated by Overview Specialists. (See pp. 4-14 and 4-15.)

3) The Discipline Specialist could determine that the Project had previously identified the substance of'the assertion for reso-lution. This determination was based on an examination of Project documentation and was governed by the criteria listed in Attachment 4-G. The types of Project documentation that could be relied upon for this purpose were defined by- HL&P (see Appendix D); they are documents maintained as part of the official STP Project records. Assertions of deficiency resolved or identified for resolution in Project documentation were considered closed for the purposes of the Litigation Record Review Program. (See,- by way of example, the sample Disposition Forms on pp. 4-J-11 and 4-J-13.)

l

4) Finally, the Discipline Specialist reviewed any assertion of l deficiency not disposed of as described above to determine l

whether it was factually erroneous. In making 'this deter- )

mination, the Discipline Specialist applied the decision cri-teria in Attachment 4-H. Assertions determined to .be i

4-12 I

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i

factually erroneous were considered closed. (See, by way of example, the sample Disposition Form on p. 4-J-15.)

Discipline Specialists were encouraged to communicate with one another as well as with the Overview Specialists and Team Leader (and his designees) to resolve potential interdisciplinary concerns.

The Discipline Specialists recorded the disposition of assertions of deficiency on Disposition Forms. A single Disposition Form could be used to dispose of more than one assertion if the assertions referred to the same deficiency.3 The handwritten copy of this Form was provided to SLI Computations for entry into SLI's data base system. SLI Computations then provided the Discipline Specialist with a computer printout of the form. The Discipline Specialist checked the printed form for accuracy and signed it; this became the official Disposition Form, and was filed with the Records Center. Any subsequent changes to the Disposition Form were made by formal revisions. All versions are retained by the Records Center.

Under the procedures governing the Litigation Record Review Program, any assertions of deficiency that were not determined not to be safety-related, were not shown to have been identified for resolution in Project documentation, and could not be shown to be factually erroneous ,

were to be documented on an HL&P Deficiency Evaluation Form. All Deficiency Evaluation Forms were to be sent to HL&P STP Engineering for evaluation in accordance with existing Project procedures. In fact, no such assertion was identified.

3I n some cases a single Disposition Form was used to dispose of asser-tions describing different deficiencies but subject to the same disposi-tion because they were addressed in the same Project documents or pertained to the same specific SSC.

4-13 i

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s

.k

c. Second-Level Reviews by Overview Specialists Any statements found by a Discipline Specialist not to meet the

! criteria for identification of assertions and any assertions determined not to be safety-related were' subject to a second level of review by the Overview Specialists. The Overview Specialists were organized into ' a single Overview Squad. Work assignments within the Squad were made by the Overview Squad Leader who had the same qua'lifications that were required for the position of Team Leader.

Those statements determined by the Discipline- Specialists not to constitute assertions were reexamined by Overview Specialists, w'io again applied the " Criteria for Identification of Assertions of Deficiency" (Attachment 4-E) to verify that the Discipline Specialist was correct in

)

his determination that the statement was not an assertion of deficiency.

] Where the Overview Specialist concluded that a statement had properly been determined not to constitute an assertion, he documented his deter-mination on an Overview Disposition Form (see the sample Overview l Disposition Form on p. 4-J-3), and no further review of that statement was performed. If the Overview Specialist determined that the statement did constitute an assertion of deficiency, the assertion was reassigned to the Discipline Specialist for disposition as an assertior, of defi-J ciency.

All assertions of deficiency that were determined by a Discipline Specialist not to be safety-related were also reviewed by. Overview Specialists. Using the criteria in Attachment ~ 4-I, the Overview Specialist determined whether the assertion presented concerns arising out of systems interaction considerations or from the possibility that the substance of the assertion crossed discipline lines. Where such concerns were determined-to be present, the' assertion was assumed to be i

safety-related and was treated as if it were safety-related. That is, the substance of the assertion was examined by the Overview Specialists 4-14 A

.<~

l to determine whether the substance of the assertion had already been I identified by the South Texas Project or whether it is factually erro-neous, using the criteria in Attachment 4-G and 4-H. The results of these determinations were documented on Disposition Forms in the same manner as was done by Discipline Specialists. (See, by way of example, the Overview Dispcsition Form on p. 4-J-6.) Where concerns for systems interaction or possible crossing of discipline lines were not present, the assertion was treated as not safety-related by the Overview Specialists who documented this result on Disposition Forms in a manner similar to that of the Discipline Specialists. (See, by way of example, the Overview Disposition Form on p. 4-J-9.)

The Overview Specialists were encouraged to consult with other Overview Specialists, Discipline Specialists, or the Team Leader to maintain awareness of the various types of asserted deficiencies being examined during the review process. Under governing procedures, any assertions that were safety-related but that could not be shown to have been identified in Project documentation and were not shown to be fac-tually erroneous were documented on a Deficiency Evaluation Form and sent to HL&P STP Engineering for evaluation in accordance with existing STP procedures.4 In fact, no such assertion was identif.ied.

d. Administrative Control of S. Levy Incorporated Review Process SLI's detailed review of selected litigation record materials was conducted under formal administrative controls (see Procedure LRP-4 in Appendix C). They provided a means of measuring compliance with review procedures while the review process was under way, thus permitting early identification of the need for any remedial or corrective action. They also provided a means for determining whether the finished product of 4

Assertions determined not to be safety-related were nonetheless referred to the HL&P Manager, Nuclear Licensing.

4-15

each phase of work complied with procedures, again facilitating iden-tification of the need for any rework.

Under the administrative controls,'at least ten percent of all SLI review work, including a portion of the work performed by each Reviewer, Discipline Specialist, and Overview Specialist, was required to be eval-uated by individuals qualified to the level of the Team Leader. In fact, this minimum requirement was significantly exceeded.

Evaluation of Reviewer's work consisted.,o.f a line-by-line review of the litigation record document reviewed and annotated by the Reviewer and the resulting Assertion and NRC Citings Forms and preparation of check lists showing whether the original work complied with procedures.

All departures from procedures were corrected.5 Evaluation of Discipline Specialists and Overview Specialists con-sisted of an assertion-by-assertion review of the appropriateness and completeness of the disposition and preparation of check lists showing whether the original work complied with procedures. All departures from-procedures were corrected.

Early in the review process, the results of evaluations of Reviewers' work showed that not all assertions of deficiency in the reviewed litigation record documents were being recorded by Reviewers.

As a consequence, a stop-work order was issued by the Team Leader on October 2, 1985, and remedial measures were implemented. These measures included retraining of all Reviewers and individuals performing evalu-ations and reperformance or evaluation (equivalent to reperformance) of all review work done to that date. Subsequent comparative analysis of the evaluation of work performed' prior to. the retraining and after 5N ote that the nature of the evaluation process as explained above is equivalent to reperformance of the work.

~ 4,-16

retraining showed that the retraining was effective. The effect of the retraining was to significantly reduce the number of instances in which assertions were not properly recorded. Because, during retraining, Reviewers were instructed to record even those statements appearing to fall only marginally within the " Criteria for Identification of Assertions" (see Attachment 4-E), the retraining also resulted in an increased occurrence of the Reviewers recording as assertions statements which did not meet these criteria. This result was found acceptable because, during the dispositioning phase, these statements would be identified and disposed of by the Discipline and Overview Specialists.

Each occurrence of an assertion not being recorded which was dis-covered during evaluation af ter the retraining was examined. In all cases, it was found that the substance of the assertion had been recorded elsewhere in the Reviewer's review of the document or elsewhere in the review of the litigation record documents. Based on this obser-vation, the review for assertion phase was found to be acceptable.

Additionally, the results of the evaluations of each Reviewer's work were examined to assess the proficiency of the individual Reviewer.

If his proficiency was found suspect, additional evaluations of his work were performed until the acceptability of his performance had been established or all of his work was evaluated and hence corrected.

Examination of the evaluation of the work of the Discipline and Overview Specialists showed that the' occurrence of departures from pro-cedures were few. It was also found that in each case the South Texas Project was aware of the substance of the assertion, or the assertion was not safety-related, or the statement wds not an assertion of defi-ciency according to the criteria (see Attachment 4-E). Thus, the disposition phase of the work was found to be acceptable.

4-17

k

4. Completion of the Work and Issuance of the Report The work of the Discipline and Overview Specialists was completed

-on February 15, 1986. Compilation and analysis of review results took place .in January and February 1986. This Report was issued on. '

February 24, 1986.

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i 4-18

l Attachment 4-A I

OUTLINE OF LITIGATION RECORD REVIEW PROCESS All:

o lnlerrogetory answers o Deposition franscripts o Expert reports Identified appropriet.e docume,n,ti for is etion tion i SCREENING record rvview proce seldcted 1 documents 4

Identified all assertions INITI AL REVIEW of deficiencies in 57P structures, syste ms, and essdrtion " mPonents forms i 4

Evaluated all DISPOSITION REVIEW essertions for ,

eppropri,efe intrediscipline r Interdiscipline hP$ ns Ne"I $o [gp meefs essertion "U criterip5  ? -MO-*critermeets e esfertion

_t_

J3 o DF safe ty."relsfed ?-no-> interdisciplinary -no 7* In erac oW project project

• l docume,ntefion?-yesldocumentefion ?--J'S DF n DF i factuel erroneous?-yes factually erroneous ?-yes-no DF ro DF i 4 -

u i defic ene evaluepon form l

SLI TEAM LEADER Transmits defeils on all fecivellv correct and

+

safety ftlated asseffiedions ni Previously ident l

HL&P STP ENG'R'G MG R

~

note: pFj = Disposition Ferm 4-A-1 ,

1

Attachment 4-5 CRITERIA FOR SELECTION OF INTERROGATORY ANSWERS FOR REVIEW A. When there is any reasonable doubt as to whether an. interrogatory or set of interrogatories should be included, it should remain on the list of interrogatories to be reviewed.

B. If an interrogatory requests information on the following subjects, 4

that interrogatory must be included for review:

1. Engineering for STP, including engineering analysis and the des'ign of any systems, structures, or components for the l Project; I

2. Construction work at STP; l

3. QA or QC activities or programs for STP;

4. Reviews or reports on engineering or construction for STP.

C. If an interrogatory or entire set of interrogatories requests information onljt about the following subjects, the interrogatory or set of interrogatories may be excluded from review unless the 1

reviewers are aware that the answers or set of answers contains l

1 1

4-8-1 l

l 1

. - . _ . - . - - . - - _ . - - . . ~ - . . . - - . - . - . ,

i information relating to the design or construction of STP systems, structures, or components.1

1. Halliburton control over Brown & Root, 1

)

2. Accounting, economics. and the financial ability of the co-owners to complete the Project;

3. Brown & Root personnel qualifications, turnover, and staffing 1 levels;

4. Project schedule and the percentage of engineering or construction work completed;

5. Allen's Creek Nuclear Generating Station;

6. Brown & Root's history and experience as an architect / engineer outside its performance on STP;

7. HL&P's or the other co-owners' experience in design and construction of facilities other than STP;

8. Brown & Root's and Halliburton's affiliation with NUS, Ebasco, l or other Halliburton subsidiaries.

1 1f an interrogatory or a set of interrogatories requests information on these topics and on any of the topics listed in B. above, the answers (

corresponding to those interrogatories must be reviewed.

(

4-8-2 i 1 l

( Attachment 4-C CRITERIA FOR THE SELECTION OF DEPOSITION TRANSCRIPTS FOR REVIEW A.

When there is any reasonable doubt as to whether a deposition should be reviewed, it must remain on the list of depositions to be reviewed.

B.

If the witness held any of the following positions on STP, the deposition must be included for review:

Engineer, Designer, Draftsman or any Engineering Management post-tion; Qaality Assurance Inspector, Supervisor or Manager; Quality Control Inspector, Supervisor or Manager; Construction Manager, Laborer or Craf t Worker; Licensing Engineer, Supervisor or Manager; Purchasing / Procurement Personnel.

C.

Depositions of witnesses in the following categories can be excluded from detailed review, unless the screener knows that any of the 4-C-1

deposition testimony related to the technical adequacy of STP design or construction:

Department of Justice employees aad former employees; Person deposed solely because of their involvement in D0J v.

Halliburton; Halliburton Board Directors and Executive Officers; Nuclear Regulatory Commission employees and former employees; Scheduling and project controls witnesses; Accounting, economics and financial witnesses; Brown & Root Board Directors and Executive Officers; I

CPLL Board Directors and Executive Officers; HL&P Board Directors and Executive Officers; City of Austin officials; City Public Service Board of San Antonio officials.

1 1

D. If the deposition is a Rule 201 deposition or a segmented personal deposition, it can be excluded from detailed review if the subject l

. of the deposition is one of the following, unless the deponent held 1

4-C-2

-e-- - - - - - - ---~e- -- ,- < , , -, ----w, - < ,,-,,m ,-m, rp---a,,, -r--,-,,e, ,-,,,m,~wn--- -

one of the positions listed in 8. above, or unless the screener knows that any of the deposition testimony related to the technical adequacy of STP design or construction:

Halliburton control of Brawn & Root; Halliburton, Brown & Root, or HL&P accounting; I

Financial constraints on completion of the Project; Brown & Root Personnel qualifications, turnover, and staffing levels; Project Control (tracking progress of work on.STP against published schedule);

Negotiations and Terms for the contract between the STP Owners and Brown & Root; Brown & Root and Halliburton's affiliation with NUS; Administrative retters concerning document collection and produc-tion in the litigation; Project Cost Estimates; 1

The Department of Jostice v. Halliburton antitrust suit; Pubile Relations and Marketing; I i

l 4-C-3

Site Access for Construction.

E. Rule 201 or personal segmented depositions may not be excluded from detailed review if the subject of the deposition concerns any of the following:

Any STP system, structure, or component; QA/QC activities or documentation whict relate to any STP system, structure or component; Reports or reviews concerning the quality :#f STP engineering, construction or QA/QC of any STP system, strccture or component.

l l

4-C-4.

e

.s__- ,_,. , _ _ . _ . , *_ __ _ ,m.- , . _ _ _ ,-. . , . _ - _.

Attachment 4-D I

CRITERIA FOR SELECTION 0F EXPERT REPORTS FOR REVIEW l A. When there is any reasonable doubt as to whether an expert report should be included, it should remain on the list of documents to be reviewed.

B. If an expert report contains information on the following subjects, that expert report must be included for review:

1. Engineering for STP, including engfr- '

analysis and the design of any systems, structures, or compo. ~sr the Project; l

2. Construction work at STP; 3.

QA and QC findings that indicate deficiencies in STP engineering or construction products; 1 l

4 Reviews or reports on engineering, QA/QC, or construction for STP.

1 4-0-1

- - ~~- ' ~~' ~ ~ ~ ~ '

I

i I

i l

C. If an expert report requests information only about the following subjects, the expert report may be excluded from review unless the reviewers are aware that the expert report contains information relating to the design or construction of STP systems, structures, or components.1

1. Halliburton relationship with Brown & Root;

2. Accounting, economics, cost estimates, and damages quantification; ,

l

3. Brown & Root personnel qualifications, turnover, and staffing '

l levels; l i

4 Evaluation of processes or procedures such as procurement or deft-ciency trend analyses; I

5. General nuclear industry information not specifically related to the STP.

l fi an expert report contains information on these topics and on any of the topics listed in 8. above, the expert report must be reviewed. )

l l

4-D-2 l 1

1

l Attachment 4-E CRITERIA FOR IDENTIFICATION OF ASSERTIONS OF OEFICIENCY In order to be recorded, an assertion must satisfy each of the following criteria:

1. The assertion must pertain to at least one of the following or to their associated design or quality control documents:

1.1 STP systems, structures, or components (SSC).

1.2 Classes of STP SSC (such as valves, reinforced concrete walls, electric systems).

1.3 Processes relating to specific STP SSCs (such as 1

)

welding, coatings).

1.4 The overall STP site (data or studies on meteorology, seismology, demographics,etc.).

2. The assertion must either:

(a) Describe a deficiency. A deficiency is a defect which will or may impair the ability of an SSC to perform its intended function; or 4-E-1 l

(b) If the assertion does not include any specific deficiency, as defined under (a), it must pertain to documents providing objective evidence of the quality of design or construction i

for specific $5Cs at STP. (Absence of calculations for system X, lack of verification documents for component Y, incomplete Q/C records for weld N, etc.)

3. The assertion must satisfy one of the following criteria:

i 3.1 It was made by a witness in a deposition.

3.2 It was confirmed by a witness accepting a statement by a lawyer.

1 3.3 It was included in an expert report. l 3.4 It was made by a party in an interrogatory answer.

4-E-2

__,y , _ . - . _ _ . . _ . , , _ . , , , . - , , - , - _ _ _ , . . _ , , , ,.-.m _. , _ - _ . . _ _ . , , _ _ . . _ _ , . , , . _ _ . , . ,,_,.__7__.._._, , ,,-..y-,, _ , ,

l Attachment 4-F l

1 CRITERIA F02 SAFETY DETERMINATION l

1. An assertion of deficiency that involves system (s). l structure (s) or component (s) which have been classified by the South Texas Project as one of the following is a safety-related assertion:

Safety Class 1 Safety Clast 2 Safety Class 3 Class 1E Seismic Category 1

2. I An assertion of deficiency that involves system (s), l j structure (s) or component (s) that are listed in the STP FSAR

]

Section 3.2 or in the Bechtel Energy Corporation Design l Criteria for the South Texas Project as safety-related items.

is a safety-related assertion.

I i

1 4-F-1  !

i

)

3. An assertion of deficiency that involves system (s),

structure (s) or component (s) with a Total Plant Numbering  !

System (TPNS) number that designates a safety-related item '

l (1, 2, 3, 4 or 5) is a safety-related assertion. l l

1 1

l l

l L

t 4-F-2 l

Attachment 4-G CRITERIA FOR DEMONSTRATING STP IDENTIFICATION

1. The STP documents cited by the Specialist as evidence of prior identification of the substance of an assertion by the STP must completely cover the specific assertion of deft-ciency.

2. The STP documents cited by the Specialist must show:

a. That the deffelency asserted has been corrected; or

b. That the deficiency asserted is in the process of being corrected; or

c. That the deficiency asserted has been identified for

resolution.

3. Documents cited as reflecting corrective action or iden-i  !

i tifIcation for resolution of the asserted deficiency must j

appear on the Itst of documents approved for reference on Disposition Forms.

4. The reasons why STP documentation shows adequate iden-tification or corrective action must be clearly stated by the Specialist.

4-4-1

Attachment 4-H CRITERIA FOR DETERMINATION ON FACTUAL BASIS

1. STP documentation must provide positive evidence showing the assertion to be factually erroneous. Unless STP documen-tation provides such positive evidence, the Specialist may not classify the assertion as factually erroneous.

2. The referenced STP documentation must describe the system, structure, or component as designed or constructed at or after the time the deficiency is asserted to have existed.

l 3. The reasons why the documentation shows the assertion to be factually erroneous must be clearly articulated by the Specialist.

1 I

4-H-1

Attachment 4-1 CRITERIA FOR INTER 0!SCIPLIMARY AND SYSTEMS INTERACTION DETERMINATION

1. An assertion of deffefency that involves discipline's other than ,

that of the Ofsefpline Specialist who initially determined that the substance of the assertion is not safety-related must be reviewed by the Overview Specialist to determine whether it is safety-related, ,

l 2.

An assertion of deficiency that involves system (s), structure (s),

or components (SSC) other than those considered by the Discipline Specialist in his initial disposition of the assertion as not safety-related must be reviewed by the vverview Specialist'to deternine whether it is safety-related.

3. If the SSC considered by the Discip1tne Specialist shares a com-4 ponent or a process or has physical supporting connections to another SSC, the assertion must be reviewed by the Overview I Specialist to determine whether it is safety-related.

4.

If the functional or physical failure of the SSC considered by the Discipline Specialist in dispositioning an assertion could propa- '

4-I-1

gate to other SSCs, the assertion must be reviewed by the Overview Specialist to determine whether it is safety-related.

b 4-1-2

STP LITIGATION REVIEW ASSERTION Document Document No. D087 Title  : GRIFFIN, G.

Category Assertion No. 050 Designators: PIPE Reviewer Name: NEISSEL, J.

, bekk b Date Completed: 10/07/85 Reviewer Signature Document Date: 01/14/85 Deposition Volume No. 1 Page No./Line Nos. ASSERTION 51/3-6 51/20-24 There were problems in the piping design.

Updated: 10/24/85 Disposition No. #fPoal Form No. ASRT-01 Overview Disposition No. AHM6004, l

l I

(Corresponds to Disposition Form RFP021 shown on p. 4-J-2 and Overview l Disposition Form AHK5006 shown on p. h-J-3.)

i l

I 4-J-1 I

l I I

STP LITIGATION REVIEW DISPOSITION Document No./

Assertion No. :

D087-050 Disposition No. Disposition RFP021 Categories : RP NOA 12 Specialist Name : PETROKAS, R. Status : NOA y l 1 d

4

-- T Specialist Signature Date Completed : 12/02/85 1

STP Reference Disposition i ..___ _________________ . .___

1 This statement is not an assertion of deficiency. It does not describe any specific deficiency in the piping design.

Updated

12/04/85 Form No. DIS-01 1

< i (Corresponds to Assertion Form D087-050 shown on p. k-J-1 and Overview {

Disposition Form AHK5006 shown on p. 4-J-3.) l 4-J-2 i

. ,_ _ , ._ . . _ _ _ _ . . . _ _ . . , . , , , . . . _ _ , . . . . _ . , - . . . - . . _ , _ __. .____..-.__.__-.,.-.-,m., . _ . .

STP LITIGATION REVIEW OVERVIEW DISPOSITION Document No./

Assertion No. :

D087-050 Overview Disposition Disposition No. AHK5006 .

Categories : RFP021 Overview specialist Name : KLOSE, AL Status : NOA Overview Specialist Signature Data Completed : 01/27/86 STP Reference Disposition This statement is not an assertion of deficiency.

It does not describe any specific deficiency in the piping design.

Updated : 01/30/86 Form No. DIS-03 i

(Corresponds to Assertion Form D087-050 shown on p. 4-J-1 and Disposition Fors PJP021 shown on p. k-J-2. )

l 4-J-3

STP LITIGATION REVIEW '

ASSERTION Document Document Number D136 Title  : LUDWIG, M.

Category Assertion No. 031 Designators: PIPE Reviewer Name: DORMIDO, R.

~

v Dat.e Completed:

, Reviewer ETgnature 09/23/85 Deposition Date: 03/27/85 Deposition Volume No. 1 Page No./Line Nos.

__________________ ASSERTION '

165/5-7 166/2-12 The deponent stated " The water line to the thrust bearings on the river makeup pump vibrated excessively, not being restrained properly."

Updated: 09/26/85 Disposition No. #FPod/

Form No. ASRT-01 overview Disposition No. A # # M 01 l

l l

(Corresponds to Disposition Form RFP-001 shown on p. k-J-5 and Overview Disposition Form AHK0001 shown on p. 4-J 6. )

i 4-J-4 i

STP LITIGATION REVIEW DISPOSITION Document No./

Assertion No. :

D136-031 Disposition No. Disposition RFP001 Categories : RFP NS 12 Specialist Name : PETROKAS, R. Status : NS A /

s

). .

I

__ ___.d.l__ __________.----------

Specialist Signature Date Completed : 12/02/85 STP Reference

_ _________________ Disposition 1)FSAR Section ...______ ...._______ ____ .

2.4.8.1.5 The substance of this assertion is not safety-related.

2)Bechtel STP The Reservoir Makeup Design Criteria System is not a safety-related system.

9Y500MQ1039, REV. O Failure of any of its components does not affect the safety of the nuclear plant.

Updated : 12/03/85 Form No. DIS-01 (Corresponds to Assertion Form D136-031 shown on p. 4-J-4 and Overview ,

Disposition Fors AHK0001 shown on p. k-J-6. )

4-J-5

- . . . - __ _ _ __ - , . _ . . . . - . _, _ ._,- ,_e-

STP LITIGATION REVIEW OVERVIEW DISPOSITION Document No./

Assertion No. :

D136-031 Overview Disposition Disposition No. AHK0001 Categories : JJH RFP001 Overview Specialist Name : HOGLE, J.J. Status : CO Overvie Sp iali t Signature Data Completed : 01/21/86 STP Reference Disposition The substance of this assertion has already 1)ST-HL-13382 been recognized in STP documentation.

Attachment RMPF HL&P is cognizant of the vibration problem ,

Interim Startup of the pump thrust bearing cooling water Report, Sec. II.4.F piping as reported in the reference [

document. t r

Updated : 01/28/86 '

Form No. DIS-03 i

f i

(Corresponds to Assertion Form D136-031  ;

Form RFP001 shown on p. k-J-5. ) shown on p. 4-J k and Disposition

{

4-J-6 '

t i

s s STP LITIGATION REVIEW ASSERTION Document Document No. D639F Title  : B&R'S 9th set to HL&P (Supplemental 2nd answers)

Category Assertion No. 034 Designators: C&S FNDT l

haviewer Name: DORMIDO, R.

\ 70 Date completed:

Raviewaf Signature 11/22/85 Document Date: 02/01/84 Deposition Volume No. 871 Page No./Line Nos.

---

ASSERTION 7/20-22 -----------------------------------_--_----------

Bechtel Work Package No. EC-157: B&R's sole plate design for the pump in the Plant Inorganic Wastes Basin did not conform to the pump vendor's requirements.

Updated: 11/26/85 Disposition No. MSM8 Form No. ASRT-01 Overview Disposition No. AMM 3[./[

(Corresponds to Disposition Form RS298 shown on p. 4-J-8 and Overview Disposition Form AEK3615 shown on p. 4-J-9. )

4-J-7

STP LITIGATION REVIEW DISPOSITION Document No./

Assertion No. :

D639F-034 Disposition Disposition No. RS298 Categories : 85 NS Specialist Name : SRINIVASAN, RAM Status : NS M G48W%

Specialist signature Data Completed : 12/18/85 1

i i

i STP Reference Disposition

] 1) Bechtel STP ___ .___..___________________..____________.

Design Criteria The substance of this assertion is not safety-related. The inorganic waste system Manual, Vol. II 9Y250SQ1021-0 is part of the sanitary waste (Ref. 1) which is not safety-related. -

1 Updated : 12/26/85 Form No. DIS-01 i

i l

l (Corresponds to Assertion Form D639F-034 shown on p. k-J-7 and Overviev Disposition Form AHK3615 shown on p. h-J-9. ) j 1

I l

l 4-J-8 i

( _ , _ . _ . _ . . . _ . _ .- . _ , - - - - - --- -- -- "' ~ -~ ~ " ~ ~ ~ ~ ~ ' ~ ~ ' ' '

STP LITIGATION REVIEW OVERVIEW DISPOSITION Document No./

Assertion No. :

D639F-034 overview Disposition Disposition No. AHK3615 , Categories : REK RS298 overview Specialist Name : PETROKAS, R. Status : NS J1 -

I-overview specialist signature Date Completed : 01/23/86  ;

l STP Reference Disposition The substance of this assertion is not 1 safety-related. There are no plausible systems interaction or interdisciplinary effects arising from the asserted deficiency which would impair the ability of a safety-related SSC to perform its 1)Bechtel STP intended function.

Design criteria, The assertion concerns part of the Sanitary Vol. II, Waste System which is not safety-related 9Y250SQ1021, Rev. O per the Bechtel Design Criteria.

Updated : 01/24/86 Form No. DIS-03 (Corresponds to Assertion Form D639F-034 shown on p. 4-J-7 and Disposition Form RS298 shown on p. 4-J-8. )

l 4-J-9

STP LITIGATION REVIEW l ASSERTION  !

Document Document Number D087 Title  : GRIFFIN, G. l Category Assertion No. 047 Designators: RES Reviewer Nare: NEISSEL, J.

. 4 416 Date Completed:

V R'eviewer Signature 09/23/85 i

Deposition Date: 01/18/85 Deposition Volume No. 4 l

Page No./Line Nos. ASSERTION

____________ _____ l 523/25 524/1-6 The deponent stated: "There was a problem concerning filling the main reservoir, and the hydrostatic pressure from the main reservoir lifting out or blowing out the liner, the clay liner, in the essential cooling water reservoir."

Updated: 10/01/85 Disposition No. N30b7 Form No. ASRT-01 '

Overview Disposition No. Alone femti d o

(Corresponds to Disposition For:2 RS067 shown on p. I -J-11. )

4 4-J-10

STP LITIGATION REVIEW DISPOSITION Document No./

Assertion No. :

D087-047 Disposition No. Disposit. ion RS067 Categories : 57 Specialist Name : SRINIVASAN, RAM Status : CO Mb Specialist Signature Date Completed : 12/05/85 STP Reference Disposition 1)IRC Item 36 ___________________________________________

ST-HL-16353 The substance of this assertion has already been recognized,in STP documentation.

Reference 1 states that the deficiency concerning high hydrostatic pressure in the ECP is considered closed.

4 Updated : 12/10/85 Form No. DIS-01 (Corresponds to Assertion Form DOBT-OkT shown on p. k-J-10. )

1 k

4-J-11 l

STP LITIGATION REVIEW I ASSERTION Document Document No. D106 Title  : RICE, W.

Category Assertion No. 010 Designators: MEAB I l

Reviewer Name: ABDOLLAHIAN, R.

f l &,3. e_v///\

e

, \ _ l_ lt

~

Date Completed: 10/27/85 Reviewer Signature' Document Date: 06/01/84 Deposition Volume No. 4 Page No./Line Nos.

---

----- ASSERTION 668/1-17 There was a 1-ft surveying error on the Unit 2

. Mechanical Auxiliary building.

Updated: 10/30/85 Disposition No. #SoolD Form No. ASRT-01 overview Disposition No. d)dM N surr M 0

i l

l (Corresponds to Disposition Form RS001D shown on p. k-J-13. )

i I

4-J-12

STP LITIGATION REVIEW DISPOSITION

__~__________________

Document No./

Assertion No. : l D002-015 D003A-002 D012-001A D012-009A D018-001 D021-007 D032-026 D060-008A D076-005 D077-001 D082-017 D100-009 D100-011 D100-020 D101-003 D102-002 D106-010 D119-002 D126-001 D128-002 D128-004 D128-005 D134-001 D134-002 D134-003 D134-004 D134-005 D134-006 D135-016 D172B-001 D176-004 D176-030 D176-040 D600-032 D603-001 D605-001 D606-017 D607-001 D613-002 D625-001 D625-002 D632-032 D672-010 D672-011 Disposition Disposition No. RS001D Categories : 32 Specialist Name : SRINIVASAN, RAM Status : CO

\

Specialist Signature Date Completed : 02/19/86 STP Reference Disposition 1)NCR# S-C657 ___________________________________________ )

2)ST-ML-AE-384 The substance of these assertions has been (10/29/79) recognized in the STP documentation. The deficiency has been documented in Ref. 1. <

Even though the deficiency was not reportable to the NRC, HL&P prepared a report to the NRC (Raf. 2) regarding the dimensional error problem. The corrective action included the redesign of the Unit 2 MEAB to compensate for the one-foot error and the addition of another tier of supervision.

Updated : 02/22/86 Form No. DIS-01 l (Corresponds to Assertion Form D106-010 shown on p. 4-J-12. )

4-J-13

STP LITIGATION REVIEW ASSERTION Document Document No. D100 Title  : HARDT, M.

Category Assertion No. 003 Designators: REPH Reviewer Name: SUMMERS, H.

N= - Date Completed:

Reviewer Signature -- 10/15/85 Document Date: 08/28/84 Deposition Volume No. 4 Page No./Line Nos.

______________ ___ ASSERTION 639/3-18 ____________ _______ ____ ________ ____________ _

The use of boron carbide can "... degrade over time and cause [ sic) attendant problems with reduced control margins."

l i

Updated: 10/31/85 Disposition No. (smR3008 Form No. ASRT-01 Overview Disposition No. 4;/k'5W4 i

(Corresponds to Disposition Form GMR3003 shown on p. 4-J.15. )

4-J-14

I l

t STP LITIGATION REVIEW I DISPOSITION 1 Document No./  ;

Assertion'No. :

D100-003 Disposition Disposition No. GMR300B . Categories : FE Specialist Name : ROY, G.M. Status : FE k---------------------- Date Completed : 12/13/85 Spe9ialist Signature STP Reference Disposition 1)FSAR Section 4 This assertion is factually erroneous. STP Figures 4.2-9 and l 4.2-10 uses hafnium, not B4C, as the control rod i material.

Updated : 02/05/86 i

Form No. DIS-01 l

l l

l (Corresponds to Assertion Form D100-003 shown on p. 4-J-14. )

l 4-J-15 l

l i

Attachment 4-K LITIGATION RECORD QEVIEW FLOW CHART l Cate rize depositions nq Does the statement recorded ne tsechons,and , a - b the 9eviewer meet tne interrogatory answers, teria forleentification of i 1

(TL) no Assertion of Deficiency ?-

4 see . gp.s),(g$)

END 4 yc3 AssiAn Cate.eorized ma4Fiel to Mviewer. -

Erassian assertion to (TL) DiSciptfne Specialist. (TL)

E i

Read review materialand - ASSien qroupsofessertions record all assertions of a no - to D'/er,ra Specialist. (y()

in er deficiencgSTP.

const. o ge. and . l ,

) 4 i Does assertion involve more 4

no ttlan orie discipline, systeE. ,

structure.orcomponent l 4

essNihnsio D cipline END (05)

Specialist by category. 4yes b}

Consideri the infer-4 cisciplina . nature of no asserti n* is it safet -

Does the statement recorded 102 Y by the Reviewer meet the END related h (05)

"Criferia for identificstion 4 yes orcorr unok ofI.ssertion of Defciency ?* ndentif ro'ect document-

/see LEP-Q. (DS) 4yes

+ stanceation Ni acoresses sub-of essertion. m 's'th* * .

• d '"**"*'

tion'ol" '** fence of the 85 5 8'+' "

Group tosether Assertions (DS) (OS) tnet len64nemselves to the is Y 4 no same Disposition.(95) END_ m is asser+iograciuelty E Identif pro , erroneous .(05) -

shon e4owngect document- F "*

• safety-relatec Isihe f

assertion 3DC) (deficiency l p IIgasseMonM J " "" "5-s f Preport DEF.(05) 4Ws

• 4 1s there p ect cocument. END afion on wbstance of Rev'$w.and

1. to $ P (7L) send DEF tne assertion ? (DS) '

4r.o identi

• 4 ect doc.ument- END  :

ation ddresses i is

""r assertionfactually

"* u' I sub ect o assertion.

• i (DS)

@ rconT Know p*S _( 5)  ;$kdKt(""Y-4 TL Team Leader  !

Prepare DEF. (DS) END q q,y;,,,r 4 identifgproject occument. DS Discipline specialist Review and send DEF to STP. a t g e usi k N eo 5) & "* ** ,* *

(TL)  ;

(05) '

4 END 4 END i 4-K-1

Section 5 QUALITY ASSURANCE A. INTRODUCTION The detailed review of selected litigation record documents per-I formed by SLI was closely monitored under Quality Assurance programs conducted by SLI's Corporate Quality Assurance Manager and a resident representative of HL&P's Project Quality Assurance department. Auditors from HL&P's QA department and an auditor commissioned by SLI also per-formed independent audits of the review. In addition, NRC Region IV inspectors performed two inspections.

B. S. LEVY INCORPORATED QUALITY ASSURANCE The SLI Quality Assurance. Program was conducted '1 conformance with SLI's standard Quality Assurance Program Manual, Rev. 1, and proce-dures issued pursuant thereto.1 SLI's' Corporate Quality Assurance Manager, who reports directly to SLI's President, directed all aspects of the SLI QA Program for the review independent of SLI's personnel assigned to perform the review.

The functions of SLI's QA Program were to monitor compliance with the contract, SLI's QA Manual, and the Plan, Procedures, and Guidelines during and at the conclusion of the review. In addition, SLI QA per-formed substantive surveillance of the litigation record review on a sample basis.

SLI's QA Program for the review was implemented initially by SLI's Corporate QA Manager and two qualified and experienced QA specialists.

15ee LRP-5 and LRP-6 in Appendix C.

5-1

These QA personnel were experienced in the QA/QC technical specialties and also had considerable experience in nuclear plant design, construc-tion, and operations. During October 1985, a third QA specialist was assigned to the Program. Each of these persons participated in formal training sessions for the Litigation Record Review Program.

Two distinct types of QA surveillance of the review work were con-ducted. First, approximately 300 conventional QA reviews were performed throughout the review process. These QA reviews consisted of the con-ventional QA/0C checks on the qualifications of personnel, the pro-cessing and control of documents, records collection and storage, and compliance with applicable SLI litigation review procedures.

Secondly, approximately 100 substantive surveillances of the review work were performed. These substantive surveillances went beyond the

{

normal application of conventional QA/QC principles in that the tech-nical bases and the logic process leading to the engineering decisions were checked for compliance, completeness, and consistency. The substantive surveillances were performed on approximately ten percent of the work product. This included examination of samples of litigation record documents reviewed, along with the completed Assertion Forms and NRC Citings Forms for those documents, to assure that all assertions and substantive references to the NRC appearing . in the litigation record l

documents were properly recorded. In addition, samples of Disposition l

Forms and Overview Disposition Forms were examined along with the  !

Project documents referenced on these forms to assure that the documen-tation adequately supported the dispositions. I 1

Issues raised or problems discovered by SLI QA during these QA '

reviews and substantive surveillances were documented in Action Item Requests (AIRS) or Deviation Reports (DRs). An AIR is used to document an apparent deviation from specific requirements or to request clarifi-cation of a specific issue.

A DR is used to document a clear deviation I

5-2 '

from specific requirements and the evaluation and resolution of that deviation. This problem definition and resolution system was utilized by SLI's QA specialists, HL&P Project QA, and other participants in the review. SLI QA Specialists participated in and monitored the evalu-ation, resolution, and close-out of all corrective action associated with the AIRS and DRs.

Three DRs and 58 AIRS were initiated. The three DRs are listed in Attachment 5-1. Each of the apparent deviations or requests for,clari-fications in the 58 AIRS was addressed, and any investigative, remedial and preventive corrective action was taken.

The SLI QA Manager prepared monthly reports for Houston Lighting and Power Company, S. Levy Incorporated, and the Senior Advisory Panel and presented oral reports at the first four Senior Advisory Panel meetings (see Section 6). At the conclusion of the review effort, SLI's QA Manager prepared a report sumarizing his findings for the entire surveillance effort. In general, it was concluded that the review had been conducted in a technically competent and controlled fashion and that the project objectives had been met.

C. HOUSTON LIGHTING & POWER COMPANY QUALITY ASSURANCE HL&P assigned a representative from the STP Project Quality Assurance organization to the SLI offices for continuous surveillance of performance of the Litigation Record Review Program. This resident representative monitored compliance with the Procedures, Litigation Review Project Plan, and Guidelines governing litigation record review work; in addition, substantive surveillance of litigation record review work was performed on a sample basis.2 2

This resident representative was assisted by a second HL&P STP Project Quality Assurance specialist who was present at SLI's offices for approximately one-half of the duration of the Litigation Record Review Program.

5-3

The HL&P Project QA personnel performed some 79 surveillances distributed throughout the entire course 'of the review. These sur-veillances covered all major aspects of SLI's porticn of the review, including the review of litigation record documents for identification of assertions and substantive references to the NRC, and disposition of assertions by Discipline Specialists and Overview Specialists.

Surveillance of these areas was conducted by means of examination of documents prepared by members of the Litigation Review Team, including Assertion Forms, Disposition Forms, Overview Disposition Forms, and.

associated documentation. Records documenting the qualification and training of the Litigation Review Team were also audited. Problems discovered during these surveillances were documented in HL&P Standard Deficiency Reports (SDRs) and provided to the SLI Team Leader for response. A total of 7 SDRs were issued during the course of the review of the litigation record. These are listed in Attachment 5-1.

HL&P's resident QA representative prepared monthly reports and pre-sented oral reports of HL&P QA activities at the first four Senior Advisory Panel meetings (see Section 6, below). At the conclusion of the review, HL&P QA issued a final report of its findings, which concluded that the program adequately met HL&P's quality assurance requirements.

5-4 l

D. AUDITS AND INSPECTIONS

1. S. Levy Incorporated Independent Quality Assurance Audits As required by its QA Program, SLI commissioned two independent QA audits of various aspects of the Litigation Record Review Program in October 1985 and January 1986. The October audit examined personnel qualifications and training records, forms prepared during review of documents for assertions of deficiency, and conformance of documents prepared to requirements set forth in the Plan, Procedures, and Guidelines. SLI Computations and SLI QA records were also audited.

This independent audit resulted in three Audit Finding Reports (AFRs) which required formal investigation and response and five Observation Reports (0Rs) which did not require formal investigation or response.

None of the Audit Finding Reports or Ob'ervation Reports was con-sidered to represent a breakdown of a quality system, and the auditors concluded that results of the audit indicated that program objectives would be successfully attained. Each of the Audit Finding Reports was responded to and satisfactorily resolved; they are listed in Attachment 5-1.

The second audit took place during January 1986. During this audit, samples of Disposition Forms and Overview Disposition Forms were examined to determine whether they were properly filled out and filed.

Records documenting SLI management evaluations of identification of assertions by Reviewers were examined, and checks were performed to verify that problems noted in these evaluations had been corrected.

Similar examinations were performed of SLI management evaluations of the disposition and overview disposition processes. The audit also examined responses to DRs, AIRS, and SDRs to verify that corrective actions had been implemented. Records in the Records Center were exam $ned to verify that hard-copy files corresponded to computer listings. _ The January 1986 audit resulted in two Audit Finding Reports (AFRs), each of which 5-5

was responded to an eatisfactorily resolved. Two Observation Reports, not requiring forma testigation or response, were also issued. The Audit Finding Reports and their resolutions are listed in Attachment 5-1.

The auditors concluded that audit results indicated that Litigation Record Review Program objectives were being successfully completed in accordance with program requirements.

2. Houston Lighting & Power Company Quality Assurance Department Audit During November 18 to 22, 1985, an audit team consisting of a lead auditor and an auditor from the HL&P QA department performed an indepen-dent audit of the SLI Litigation Review Project Plan and associated Procedures to ensure compliance to the terms and conditions of HL&P's purchase order and SLI's Litigation Record Review Program. The audit team reviewed documents prepared by SLI during the review to determine

. compliance with review Procedures, and examined filing and preparation for shipment of documents in the SLI Records Center. Samples of litigation record documents reviewed and associated Assertion Forms and NRC Citings Forms were examined to determine whether all assertions and substantive NRC citings appearing in the documents had been properly- l recorded. The HL&P QA auditors also reviewed Deviation Reports and l Action Item Requests prepared by SLI's QA organization and the resident HL&P QA supervisor. As a result of this audit, six Audit Deficiency Reports (ADRs) were issued. These ADRs and their resolutions are listed in Attachment 5-1.

E. OVERALL QUALITY ASSURANCE RESULTS Quality Assurance surveillance covered all major aspects of SLI's l detailed review of the litigation record. Although these activities  !

resulted in the identification of particular problems for resolution, 1

1 5-6

k 4

each of these was effectively addressed in a timely manner. All - QA organizations and audits concluded that'the objectives:of the Litigation Record Review Program were satisfactorily achieved., Exit interviews following the two NRC inspections indicated that the Program was pro-ceeding in an acceptable manner.

A b

e i

1 4

4 5-7 l

1

,- - -- - , * ,,-4r . , , -,,.-. - , -- - . , , , . ,,,y.- ,, - -..._.

I

)

i l

)

Attachment 5-1 l

LITIGATION RECORD REVIEW QUALITY ASSURANCE ISSUE 3

{

The following tatie lists the issues addressed by the Deviation Reports, Standard Deficiency Reports, Audit Deficiency Reports, and Audit Findlag Reports issued by the various QA organizations l which monitored the Litigation Record Review F?ogram.

No. Issue Resolution i Deviation Reports (Dks) Issued by SLI Q4  !

l DR-Col Two Individuals perforuing ravlow work Dismissal of Individuals from pegram; re- i DR-001A did not have required quellfications. assignment and reperforsence of all their i work. Rechsck of personnel quellfications.

DR-002 Fallure of Reviewers to properly This issue was detected by the evaluation record all assertions of deficioney of Reviewer's work and corrective action in litigation documents reviewed, initiated prior to issuance of Q1-002, SDP-H-201 and AFR-01 See Administrative Control of SLI Review Process, pages 4-16 to 4-18 for resolution, l

i Standard Deficiency Reports (SDRs) Issued 9y HL&P Resident On Personnel h

SLR-H-193 Camplete Instructions for how to prepare instructions included in litigation  !

nL&P DEFs not included in litigation record review procedures; DEFs no longer record review procedures; j required to be typed.

DEFs permitted to be filled out by hand '

per Instructions of Team Leader.

SDR-H-201 Fal*ure of Reviewers to properly record all assertions of defielency in litiga- See resolution of DR-002. I tion record documents esvlewed. )

SDR-F-202 SLI QA checklist not properly filed with surveillance repcrt. Checklist filed with surveillance report, 1

S DR-H-210 SL' Q4 AIR prematurely closed. Subject AIR correctly closed. SLI QA per- {

sonnel Inst ucted on closure requirements.

SDR-H-212 Performance of evaluator of Reviewer's work questioned. Evaluator shown to de correct.

SDR-H-221 Evaluation of Discipilne and Overv!ow All cases of misperformance of evaluations Specialists work did not detect all procedural deviations, discovered were corrected. Evaluation process shown to be acceptable.

SDR-H-222 Improper ref erences used on Disposition Forms.

Improper references Identitled were oorrected. Analysis performed showing that l in all known cases of Improper references, j the asserted deficiency could be shown to i have been Identifled by Project.

Audit Finding Reports (AFRs) issued By Auditor Commissioned by SLI A FR-01 Fallurs of Reviewers to properly record all assostione, of deficiency in See resolution of DR-002 I litigition record documents reviewed. j AFR-02 Corrections to assertions required as a result of evaluations were not All corrections noted in evaluations nede.

performed and filed with evaluation Requirement changed to allow confirmetton sheets in Records Center.

of corrections after filing of evaluation sheets, l

l l

5-8

[ Attachment 5-1 (continued)

& lssue Resolution Audlt FindIP2 Reports (AFRs) Issued By Audttor Conunissioned by SLI (coe.tinues)

AFR-03 Lists In litigation rev!q,w procedures 'n Lists corrected and updatisd.

error or not up-to-date.

AFR-02-01 QA checklists not filed with survell- Checklists located and properly filed.

lance reports.

AFR-02-02 Corrections to Assertion Forms required Corrections were sede.

as a result of evaluation were not yet made.

Audit Deficiency Reports (ADRs) !sond by HL&P 04 Auditors ADR-SL-1-1 SL1 procedure for certification of Lead Procedures for certification of QA Auditor no* Included in Plan. auditors added to Plan.

ADR-SL-1-2 Document storage requirements. Storage standards need not be met until delivery of final results to HL&P.

ADR-SL-1-3 Qualifications of SLI Independent QA Auditor's quellfications are acceptable.

auditor. i ADR-SL-1-4 Use of white-out and cross-outs on handwritten records, Records corrected, retralning on proper methods of correcting documents.

ADR-SL-1-5 Team Leader Instructions for filling Requirement for typed evaluation forms out evaluation forms did not require eliminated.

typing.

ADR-SL-1-6 Incomplete page and line references on Assertion and tRC Citings Forms. Corrections made to forms on which problems were noted. Reviewers Instructed as to proper page and IIne references.

1 i

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Section 6 OVERSIGHT BY THE SENIOR ADVISORY PANEL A. MEMBERSHIP AND PURPOSE HL&P selected a Senior Advisory Panel (the Panel) to monitor the progress of the Litigation Record Review Program in order to assure that the objectives of the review are achieved. The Panel consists of three members:

Mr. William W. Lowe (Chairman), founder and Chairman of Pickard, Lowe and Garrick, Inc., and former Chief of the Nuclear Engineering Section at the Atomic Energy Commission's '

Hanford, Washington facilities. Mr. Lowe has advised electric utility companies concerning design, construction, licensing, fueling, safety and/or environmental impact of about one-third of all operating nuclear generating stations in the United '

States, including consulting services provided for the STP.

Dr. Salomon Levy, President of S. Levy Incorporated, formerly in charge of engineering and manufacturing of Boiling Water ,

Reactors at General Electric Company. Dr. Levy has been . a  ;

member of review and advisory boards examining technical and '

safety issues for a number of nuclear generating stations.

Dr. Levy and his firm performed a review of Brown & Root's engineering for STF during the HL&P v. B&R litigation. '

Mr. Cloin Robertson is General Manager--Nuclear Engineering for HL&P. He was formerly Supervisor of the Engineered Safety Systems and Analysis Group for Stone & Webster which performed safety systems design and analyses for nuclear plants designed by Stone & Webster. As a Nuclear Facilities Specialist for the New York State Atomic Energy Council, Mr. Robertson par-6-1

l ticipated in a number of technical safety reviews for nuclear generating stations located in New York State. In addition, Mr. Robertson has performed design and analysis for the Navy Nuclear Program.

Mr. Lowe, Dr. Levy, and Mr. Ro'bertson, each with more than twenty years of nuclear experience, are highly qualified and knowledgeable about the STP design.

B. ACTIVITIES OF THE SENIOR ADVISORY PANEL The Panel met periodically for discussions with the Team Leader, Reviewers, Discipline Specialists, and Overview Specialists as well as representatives of the SLI and HL&P QA organizations. In addition, the Panel examined written submittals and documents created during the liti-gation review process. During the course of the litigation record review, the Panel made suggestions to the participating SLI and HL&P organizations to help ensure achievement of the objectives of this effort.

1. October 3, 1985 Meeting The Panel received a report on thre process by which documents in the litigation record were screened to select those which might contain assertions about deficiencies in STF systems, structures, and com-ponents. The document storage and control area (Records Center) in SLI's offices was toured as well as the computer facilities (Computations Center). The Team Leader described the review process including personnel qualifications, applicable procedures, project schedule, and status. The results of the internal evaluations and a QA review were discussed. Representatives of SLI and HL&P QA organizations described the QA Program Plan and its status.

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2. November 15, 1985 Meeting At its request, the Panel received additional details concerning the screening process by which documents were selected for review.

Comments received from the NRC (see Reference 1-16) concerning the Litigation Record Review Program and HL&P's intended response thereto were discussed. The Team Leader updated the Litigation Review October Progress Report. The Team Leader reported on the evaluations of work of individual Reviewers and steps taken to remedy the discrepancies found.

HL&P and SLI QA personnel reported on their activities. The exit inter-view with NRC inspectors who had been visiting the SLI offices for several days was sumarized. The Team Leader gave an overview descrip-tion of the disposition process.

3. December 19, 1985 Meeting The Panel heard a report from Dr. Levy on the results of his detailed examination of compiled screening process results. The Panel discussed HL&P's written responses to the NRC's comments on the Litigation Record Review Program and concurred with HL&P's responses.

Mr. Robertson presented a report on the identification of assertions in litigation record documents, based on his review of SLI evaluation '

materials. The Team Leader gave an updated progress report on SLI review activities, particularly with respect to the disposition of assertions. Representatives of the HL&P and SLI QA organizations reported on their activities. The Panel attended an exit interview )

which took place at the close of a week-long NRC inspection of i Litigation Record Review Program activities at SLI.

4. January 31, 1986 Meeting The Panel heard a report from Mr. Robertson based on his review of QA documents generated during the litigation record review. The Team Leader gave an updated status report on progress of SLI review activi-6-3 l

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ties, indicating that substantive review and disposition work was nearly complete. Very few assertions remained to be disposed of. The Team Leader discussed the performance of Discipline Specialists and presented an analysis demonstrating that, in all instances in which' an assertion was not properly disposed of, the Pro;iect was shown to have already identified the substance of the assertion. HL&P and SLI QA personnel reported on their activities, including results of the second indepen-dent QA audit commissioned by SLI.

5. Final Meeting The final meeting of the Senior Advisory Panel is scheduled for February 27, 1986, in Houston, Texas. The Panel plans to examine docu-ments reflecting the results of the screening process and to issue its i statement of conclusions regarding the performance of the Litigation Record Review Program. -

C. SENIOR ADVISORY PANEL CONCLUSIONS The Senior Advisory Panel reviewed the preliminary drafts of this report and furnished comments which have been considered. The Panel is expected to issue a statement shortly after issuance of this Report.

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Section 7 RESULTS OF THE LITIGATION REVIEW A. RESULTS OF THE SCREENING PROCESS The screening process resulted in the uclusion of a substantial portion of the litigation record for detailed review by SLI. Listed below are the results of the screening process for each category (depositions, interrogatories, and expert reports) of documents screened.

1. Depositions ,

a. Total number of deponents: 274

b. Deponents whose depositions were included for detailed review: 153

c. Deponents whose depositions were excluded from detailed review: 121

d. Totalnumberofdepositionvo{umes included for detailed review: 701 Checking of these results by a second screening team (see pp. 4-4 and 4-5) confirmed the accuracy of the initial screening of depositions.

2. Expert Reports

a. Number of expert reports filed in litigation: 18

b. Number of expert reports included for detailed review: 5

c. Number of expert reports excluded from detailed review: 13 i 1Deposition transcript volumes included an average of approximately 150 pages. l 7-1 I

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Checking of these results by a second screening team (see pp. 4-4 and 4-5) confirmed the accuracy of the initial screening of expert reports.

3. Interrogatories (Including Requests for Admissions)

a. Total number of individual interrogatories filed in litigation: 5,220

b. Number of individual interrogatories included for detailed review after initial screening: 2,068

c. Nu"tber of previously excluded interrogatories included as a result of checking (includes interrogatori convenience):gs

' included for administrative 79

d. Number of individual interrogatories included for detailed review after initial screening and checking:3 2,147 All depositions, expert reports, and interrogatories identified for detailed review were transmitted to SLI. Together these documents, along with appended exhibits, filled 85 26-inch file drawers. They are listed in Appendix A.

2During the checking process, it was noted that there were a number of-individual interrogatories (a total of 35) which did not require detailed review but were embedded in a set of interrogatories, the remainder of which had been included for review. To avoid generating extra bookkeeping and paperwork, it was decided to simply include all the interrogatories in such sets for further review, rather than exclude only one or two interrogatories from review. Thus, 35 of the 79 interrogatories included as a result of checking were in:luded as an administrative convenience.

3I nterrogatories were filed in sets containing one or more individual interrogatories. The 2147 individt al interrogatories were distributed through some 113 sets.

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Table 7-1 identifies the originators of the litigation record docu-i ments transmitted to SLI for review, t

TABLE 7-1 Litigation Documents Transmitted to S. Levy Incorporated for Review Depositions Source No. of Volumes

1. HL&P employee or former employee 2/9

2. B&R employee or former employee 321

3. Others 101 ,

Total 76T Interrogatory Answers r

1. Prepared by HL&P 26

2. Prepared by B&R 27

3. Prepared by Halliburton 5

4. Prepared jointly by B&R and Halliburton 18

5. Prepared by Bechtel5 1

6. Prepared by City of Austin 13

7. Prepared by City of San Antonio 11

8. Prepared by CP&L 12 Total Tff Expert Reports Source No. of Reports

1. Prepared by Plaintiffs' consultants 3

2. Prepared by other consultants 2 Total 7 Total items to be reviewed by SLI 819 4For purpose of this Report, a set of interrogatory answers is defined as all the answers filed to a particular set of interrogatories.

5 The documents filed by Bechtel were responses to written deposition questions posed by Brown & Root and Halliburton for each Bechtel work package. In form and content they are identical to interrogatory answers, and have been treated as such for the purposes of this Report.

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Thus, of the items reviewed by SLI, 305 or 37 percent were ,

generated by HL&P or Bechtel6 and 63 percent came from other sources.

B. RESULTS OF S. LEVY INCORPORATED DETAILED REVIEW

1. Identification of Assertions of Deficiency SLI Reviewers recorded a total of 5151 assertions of deficiency in the litigation record documents reviewed. A total of 5622 statements were originally recorded on Assertion Forms, but, after a two-tiered review of these statements by the Discipline Specialists and Overview Specialists, 471 were determined not to meet the criteria for iden- .

tification of assertions of deficiency. See pp. 4-11 and 4-12, 4-14 and 4-15, and Attachment 4-E. This lef t a total of 5151 actual asser- l tions of deficiency to be disposed of.7 Assertions were distrit,uted among the documents as follows: Depositions contained an average of 2.7 assertions per transcript volume; however, some volumes contained no assertions while or.hers contained as many as 61. Assertions were more i densely distributed in interrogatory answers and expert reports. No assertions were identified in 382 of the items reviewed.

The documents containing the most assertions were HL&P's responses to Brown & Root's Ninth Set of Interrogatories, Bechtel's responses to written deposition questions for each Bechtel work package and the S. Levy Incorporated Report on Brown & Root Engineering on the South 6Here and elsewhere in this section, figures given for items generated ,

by HL&P or Bechtel include deposition transcripts reccrding the testi- '

mony of HL&P personnel. ,

7The recording by Reviewers of statements later determined not be asser- ,

tions of deficiency is primarily attributable to the retraining of i Reviewers which took place in October 1985, during which Reviewers were i instructed to record as assertions even those statements appearing to fall only marginally within the criteria for identification of asser-tions.

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Texas Project. Together, these documents accounted for 2990 assertions .

or 58 percent of the total number of assertions identified. Bechtel's responses alone contained 28 percent of the total. The distribution of assertions by source is set out in Table 7-2.

TABLE 7-2 Distribution of Assertions by Source No. of Source Assertions  % of Total Depositions

1. HL&P employee or former employee 781 15

2. All others 883 17 Interrogatory Answers

1. HL&P's responses to B&R's Ninth Set of Interrogatories 1283 25

2. HL&P's responses to other interrogatories 229 5

3. Bechtel responses to written deposition questions 1427 28

4. All other interrogatory answers 264 5 4

Expert Peports

1. Prepared by Plaintiffs' consultants 280 5

2. Prepared by other consultants 4 NIL

Total 5151 100 f

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The fact that most assertions were founr4 in documents generated by HL&P and Bechtel was expected because of HL&P's position as the primary plaintiff in the STP litigation and Bechtel's role in the extensive reviews of STP design and construction that were perforrped after Brown &

Root was replaced (see pp.1-7 to 1-10). As plaintiff in the litiga-tion, HL&P sought to demonstrate that B&R breached its contract for design and construction of STP. One method of demonstrating such breach of contract was to show that there were deficiencies in Brown & Root's engineering and construction program. In discovery, HL&P sought to identify such deficiencies. Bechtel, during the reviews of B&R design and construction, had the obligation to identify technical deficiencies in B&R's design. That assertions were found principally in documents generated by HL&P and Bechtel suggests that the deficiencies had likely already been identified by the Project. The reports prepared by Plaintiffs' consultants in the litigation contained fewer assertions because of the limited scope of the areas they were asked to examine.

The assertions identified fell within three technical areas. Table 7-3, which is printed on the following page, shows the distribution of assertions by technical area.

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l TABLE 7-3 Distribution of Assertions by Technical Area

, No. of Technical Area Assertions % of Total

1. Mechanical

a. Piping, including hangers, ,

supports, restraints, etc. 372 7

b. Balance of plant steam, condensate, and feedwater components 330 6

c. Nuclear steam supply system and components 354 7

d. Pumps, tanks, valves, and other specific mechanical components 414 8

e. Materials handling and storage 149 3

f. Heating, ventilating, and air conditioning 649 13

g. Radwaste, water, and services 498 10

h. Welding 186 4

1. Paint and coatings 144 3

2. Civil / Structural

a. Concrete and concrete reinforcement 257 5

b. Structural and miscellaneous steel 121 2

c. Anchor bolts and embeds 117 2

d. Building layout and fenestrations 329 6 i e. Site / soil 178 4

3. Electrical

a. Instrumentation and controls 373 7' ,

b. Cables, ducts, trays, and penetrations 245 5

c. AC power distribution system 242 5

d. DC power distribution system 76 1

e. Radiation detection, industrial pro- 117 2 tection, and ancillary systems Total 5151 100 l

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Nearly one-half of the assertions pertained to areas which had been extensively reviewed during the period of the 79-19 investigation and the Order to Show Cause and during the Bechtel engineering review.

Concrete and concrete reinforcement, soils, and welding were all thoroughly examined during and following the 79-19 investigation.

Heating, ventilating and air conditioning systems in most STP buildings were completely redesigned by Bechtel af ter 1981. Bechtel also sub-stantially redesigned B&R's layout of cables, trays and ducts, and re-designed or completed substantial portions of B&R's piping design, along with associated pumps, tanks and valves. Anchor bolts and embed problems had been subject to repeated examination both before and after Brown & Root was replaced. Together, these areas accounted for approxi-mately 47 percent of all assertions. Also, a very few individual de-ficiancies account for a relatively large number of assertions. For example, a one-foot surveying error made by B&R during construction of the Mechanical / Electrical Auxiliary Building is the subject of some 44 assertions of deficiency. Other such well-known items are an anchor bolt materials problem (75 assertions); the Category I soil compaction issue (39 assertions); the ability of the essent41 cooling water gantry crane to withstand high velocity winds and tornados (44 assertions); and the Brown & Root coatings issue (118 assertions). These areas were the subject of extensive examination by.the Project, and SLI found that the substarre of these assertions had been previously identified in STP documentation.

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2. Disposition of Assertions Assertions identified were dispositioned as follows:

a. The substance of 482 assertions was determined not to be safety-related and not to present interaction or inter-disciplinary concerns,

b. The substance of 4662 assertions was determined to have already been identified in Project documentation.

c. Seven (7) assertions were determined to be factually er-Toneous.

The 482 assertions that were determined not to be safety-related i were not further examined to determine whether the Project had iden-tified those items. Of the remaining assertions, 4662, or 99.9 percent, were shown to have been previously identified for resolution or resolved l in Project documentation. The final 7, or 0.1 percent, were determined to be factually erroneous. These results were not unexpected in light of the fact that the assertions were discovered primarily in litigation documents generated by HL&P and Bechtel, and in view of the interest in identifying problems in B&R's design and construction of the STP that attended HL&P's position in the lawsuit and Bechtel's role as a reviewer of B&R's design (see p. 7-6).

Table 7-4, which is printed on the following page, shows the dispo-sition of assertions from the various litigation record sources.

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TABLE 7-4 Disposition of Assertions by Source Not' Safety 8 CognizantProject Factually Source Related Erroneous Depositions

1. HL&P employee or former employee 58 721 2

2. All others 36 843 4 Interrogatory Answers

1. HL&P's rasponses to B&R's Ninth Set of Interrogatories 163 1120 0

2. HL&P's responses to other interrogatories 15 214 0 i

i 3. Bechtel responses to written deposition questions 167 1259 1

4. All other interrogatory answers 10 254 0 Expert Reports

1. Plaintiffs' consultants' repcrts 33 247 0

2. Other reports 0 4 0 Totals 482 4662

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4 8This column includes assertions found not to be safety-related and not to present systems interaction or interdisciplinary' concerns that could affect the operation of a safety-related system.

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The fact that the Project had identified all items not disposed of as not safety-related was not surprising in light of the fact that the majority of assertions were found in documents generated by HL&P or Bechtel. This high level of Project cognizance is also attributable to the fact that many assertions are related to a few well-known problems.

Many of the remaining assertions were also duplicates.

Assertions disposed of on the same Disposition Form either described the exact same deficiency or, in a few cases, were discussed f a the same Project documents or pertained tc the same specific SSC as the other assertions on the form. Thus, the 5151 assertions required only 1943 separate dispositions. Of these 1943 dispositions, 84 percent included assertions that had been found in litigation documents generated by HL&P or Bechtel. Because assertions on the same Disposition form usually described the same deficiency, this demon-strates that even those assertions contained in litigation record docu-ments generated by other organizations were for the most part repetitive of assertions found in record documents generated by HL&P and Bechtel.

Table 7-5 illustrates the disposition of assertions by technical area.

TABLE 7-5 Disposition of Assertions by Technical Area Technical Area Disposition of Assertions Percent Percent Percent Not Safety- Project Factually Related Cognizant Erroneous

1. Mechanical 11.9 88.0 0.1

2. Civil / Structural 5.3 94.5 0.2

3. Electrical 5.8 94.0 0.2 Average for all assertions 9.4 90.5 0.1 1

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In sum, all of the assertions were determined either not to be safety-related, to have been previously identified or resolved in STP documentation, or to be factually erroneous. More than 90 percent were shown to have been previously identified in STP documentation. This result is reasonable in view of the unusual level of scrutiny to which the STP design and construction have been subjected and the fact that the documents found to contain most assertions were prepared by Bechtel and HL&P or recorded the testimony of HL&P personnel.

The process by which these results were developed was subject to a number of independent checks, including resident QA programs conducted by SLI and HL&P (see Section 5), and oversight of the Senior Advisory Panel (see Section 6). In addition, SLI management for the review eva-luated the performance of each stage of SLI's review (see pp. 4-15 to 4-17), and the NRC performed two inspections during the review. Each of these checks provided assurance that the review process functioned properly and produced accurate results.

Finally, a detailed record of the review occupying approximately 220 file drawers has been retained as a permanent record of the work.

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Section 8 CONCLUSION The STP Litigation Record Review Program was a detailed, comprehen-sive and systematic examination of those portions of the HL&P v. B&R litigation record which were likely to contain assertions of deficien-cies in STP systems, structures, or components and their associated design and quality documents. The review did not disclose any pre-viously unrecognized safety-related deficiencies in STP systems, struc-tures, or components. The results of the review demonstrate that safety-related deficiencies asserted in the litigation record have already been identified by Bechtel, Ebasco, or HL&P. Given the number and breadth of the allegations arising in the litigation, this fact underscores the thoroughness and success of the earlier intensive reviews performed on the STP. Because the Program was subject to exten-sive QA and man:gement review, there is a high level of assurance that it functioned properly and produced accurate results.

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APPENDIX A This Appendix lists litigation record documents reviewed by S. Levy Incorporated.

The documents are grouped into four major types. These are:

Beginning on Document Type Page Oral Depositions A-1 Expert Reports A-46 Bechtel Responses to Written Deposition Questions A-50 Answers to Interrogatories A-64 r

The documents within each of these grcups have different charac-teristics and therefore are listed consecutively in the most convenient manner. For example, the oral depositions are listed alphabetically while the interrogatories are listed numerically by date. Other charac-teristics of each group are explained below.

Oral Depositions The oral depositions are listed alphabetically by deponent. If the deponent participated in a deposition resulting in a transcript of more

, than one volume or participated in more than one deposition, these are listed consecutively by date within the deponent's alphabetical listing.

Also, there were joint depositions. These joint depositions are listed under the name of the primary deponent with names of _other par-ticipants in the joint deposition shown in parentheses following the primary deponent's name.

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I Expert Reports Five expert reports were reviewed; the expert reports are listed alphabetically by the name of the person or organization preparing the report. The S. Levy Incorporated report consists of two volumes.

j- Because of the large amount of technical information in this report, each of these volumes was divided into separate elements by section and subsection for review purposes. .Each of these elements is listed con-secutively by volume, section, and subsection.

l Bechtel Responses to Written Deposition Questions

. The Bechtel responses to the B&R written deposition questions are arranged ' alphabetically then numerically by the Bechtel work package to which the response relates, i.e., EA-002, EC-150, etc. The- Bechtel written responses were filed during the per tod 07/27/84 through

! 11/21/84. For simplicity, the Bechtel written responses reflect only j the date the transmittals were initiced: 07/27/84. During the litiga-i tion record review and in the body of this Report, the Bechtel responses I have been treated as interrogatory answers. '

Interrogatories The answers to the interrogatories are listed chronologically by the dato the interrogatory response was filed. <

Documents Not Reviewed Finally, on pages A-71 and A-72,. there is a lis't of documents assigned to be reviewed by S. Levy Incorporated but which were not reviewed. These documents are interrogatories for which no answers were i ever filed; consequently there was no material to review.

Each set of interrcgatories listed contains at least one interroga--

tory included for review during the screening process.- There were some A- 11 f

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interrogatories for which more than one answer was filed; for others no l answers were filed. SLI review?.d all answers -filed to each individual interrogatory included for review during the screening process. .Where no answers were filed, there was no material.to-review.

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Appendix A Document Number Document Title A0001 Oral Deposition of ALEXANDER, D.; Vol.1; Dated 12/20/83 A0002 Oral Deposition of ALEXANDER, D.; Vol. 2; Dated 12/21/83 A0003 Oral Deposition of ALEXANDER, D.; Vol. 3; Dated 12/22/83 A0004 Oral Deposition of ALEXANDER, D.; Vol. 4; Dated i

02/14/84 '

A0005 Oral Deposition of ALFORD, T.; Vol.1; Dated 01/23/85 i

A0006 Oral Deposition of ALFORD, T.; Vol. 2; Dated 01/29/85 A0007 Oral Deposition of ALK0V, F.; Vol.1; Dated 09/05/84  ;

A0008 Oral Deposition of ALK0V, F.; Vol. 2; Dated 09/06/84 I A0009 Oral Deposition of ALLEN, C.; Vol.1; Dated I 12/11/84 ,

A0010 Oral Deposition of AMARAL, J.; Vol.1; Dated 10/09/84 A0011 Oral Deposition of AMARAL, J.; Vol. 2; Dated 10/10/84  :

A0012 Oral Deposition of AMARAL, J.; Vol. 3; Dated 10/11/84 A0013 Cral Deposition of ANDERSON, D.L.; Vol.1; Dated 01/15/85 A0014 Oral Deposition of ANDERSON, D.L.; Vol. 2; Dated 01/16/85 A0015 Oral Deposition of ANGST, G.; Vcl. 1; Dated 12/17/84-A- 1 l 1/21/86 4

Appendix A Document Number Document Title A0016 Oral Deposition of ANGST, G.; Vol. 2; Dated 12/18/84 A0017 Oral Deposition of ASBECK, F.; Vol.1; Dated l 02/12/85 A0018 Oral Deposition of ASBECK, F.; Vol. 2; Dated 02/13/85 A0019 Oral Deposition of ASBECK, F.; Vol. 3; Dated 02/14/85 A0020 Oral Deposition of AS8ECK, F.; Vol. 4; Dated 02/15/85 A0021 Oral Deposition of ASBECK, F.; Vol. 5; Dated 02/18/85 A0022 Oral Deposition of ASBECK, F.; Vol. 6; Dated \

02/19/85 A0023 Oral Deposition of AS8ECK, F.; Vol. 7; Dated 02/22/85 A0024 Oral Deposition of AS8ECK, F.; Vol. 8; Dated 02/25/85 A0025 Oral Deposition of AUSTIN, H.G.; Vol.1; Dated 10/04/84 A0026 Oral Deposition of AUSTIN, H.G.; Vol. 2; Dated 10/05/84 A0027 Oral Deposition of AYRES, J.; Vol.1; Dated 02/28/84 A0028 Oral Deposition of AYRES, J.; Vol. 2; Dated 02/29/84 A0029 Oral Deposition of AYRES, J.; Vol. 3; Dated 03/01/84 A0030 Oral Deposition of AYRES, J.; Vol. 4; Dated 07/10/84 A- 2 I

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Appendix A Document Number Document Title kbb3k brak behbskkkon of khREh b$$ hbi$ h$ bated 07/11/84 A0032 Oral Deposition of AYRES, J.; Vol. 6; Dated 07/12/84 A0033 Oral Deposition of BAKER, H.; Vol.1; Dated 01/17/85 I

A0034 Oral Deposition of BAZOR, J.C.; Vol.1; Dated 02/13/84 A0035 Oral Deposition of BAZOR, J.C.; Vol. 2; Dated 02/14/84 A0036 Oral Deposition of BAZOR, J.C.; Vol. 3; Dated 07/10/84 A0037 Oral Deposition of BEAVERS, A.; Vol. 1; Dated 03/13/84 A0038 Oral Deposition of BEAVERS, A.; Vol. 2; Dated

. 03/14/84 A0039 Oral Deposition of BIERMAN, G.; Vol.1; Dated 03/26/84 A0040 Oral Deposition of BIERMAN, G.; Vol. 2; Dated 03/27/84 A0041 Oral Deposition of BIERMAN, G.; Vol. 3; Dated 03/28/84 A0042 Oral Deposition of BIERMAN, G.; Vol. 4; Dated 03/29/84 A0043

Oral Deposition of BIERMAN, G.; Vol. 5; Dated 03/30/84 A0044 Oral Deposition of SIERMAN, G.; Vol. 6; Dated 04/02/84 A0045 Oral Deposition of BIERMAN, G.; Vol. 7; Dated 04/03/84 A- 3

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Appendix A Document '

Number Document Title bb4b brak bepositkon bf bhEkkkk b$; lb55 b; baked 04/04/84 A0047 Oral Deposition of BIERMAN, G.; Vol. 9; Dated 04/05/84 A0048 Oral Deposition of BIERMAN, G.; Vol.10; Dated i 04/06/84 A0049 Oral Deposition of BISHOP, J.; Vol.1; Dated i 01/19/84 I A0050 Oral Deposition of BISHOP, J.; Vol. 2; Dated 01/20/84 A0051 Oral Deposition of BLAKLEY, G. (Jordan /Blakley);

Vol. 1; Dated 09/18/84 A0052 Oral Deposition of BLAKLEY, G. (Jordan /Blakley);

Vol. 2; Dated 09/19/84 A0053 Oral Deposition of BLAKLEY, G. (Jordan /Blakley);

Vol. 3; Dated 09/20/84 A0054

, Oral Deposition of BLAKLEY, G. (Jordan /Blakley);

Vol. 4; Dated 09/21/84 A0055 Oral Deposition of BOSQUEZ, T.B.; Vol.1; Dated 08/01/84 A0056 Oral Deposition of BRAUN, G.; Vol.1; Dated 04/10/84 l

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A0057 Oral Deposition of BRAUN, G.; Vol. 2; Dated 1 04/11/84 i i

A0058 Oral Deposition of BRAUN, G.; Vol. 3; Dated 04/12/84 A0059 Oral Deposition of BRISKIN, J.; Vol.1; Dated i 01/29/85  !

i A0060 Oral Deposition of BRISKIN, J.; Vol. 2; Dated 01/30/85 l

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Appendix A Document Number Document Title bbbk brak bepbsktkon of hRkhKiN $3b53$ bated 01/31/85 A0062 Oral Deposition of BRISKIN, J.; Vol. 4; Dated 02/01/85 A0063 Oral Deposition of BROOM, K.; Vol.1; Dated 08/22/84 A0064 Oral Deposition of BROOM, K.; Vol. 2; Dated 08/23/84 A0065 Oral Deposition of BROOM, K.; Vol. 3; Dated 08/24/84 A0066 Oral Deposition of BROOM, K.; Vol. 4; Dated 08/30/84 A0067 Oral Deposition of BROOM, K.; Vol. 5; Dated 08/31/84 A0068 Oral Deposition of BROOM, K.; Vol. 6; Dated 09/18/84 A0069 Oral Deposition of BROOM, K.; Vol. 7; Dated 09/19/84 A0070 Oral Deposition of BROOM, K.; Vol. 8; Dated 09/24/84 A0071 Oral Deposition of BROOM, K.; Vol. 9; Dated 09/26/84 A0072 Oral Deposition of BURFORD, F.; Vol.1; Dated 1 11/13/84 i 1

A0073 Oral Deposition of BURFORD, F.; Vol. 2; Dated l 11/14/84 i

A0074 Oral Deposition of BURFORD, F.; Vol. 3; Dated 11/15/84 A0075 Oral Deposition of COMMANDER, B.; Vol.1; Dated 01/12/84 A- 5 1/21/86 l

Appendix A Document Number Document Title kbb76 brak bepbsktkon bf CbkkkhbhR b ; Vb5 2; bated 01/13/84 A0077 Oral Deposition of COOPER, G.; Vol.1; Dated 02/27/84 A0078 Oral Deposition of COOPER, G.; Vol. 2; Dated 02/28/84 A0079 Oral Deposition of COOPER, G.; Vol. 3; Dated 02/29/84 A0080 Oral Deposition of COOPER, G.; Vol. 4; Dated 03/01/84 A0081 Oral Deposition of COOPER, G.; Vol. 5; Dated 03/02/84 A0082 Oral Deposition of COOPER, G.; Vol. 6; Dated 05/02/84 A0083 Oral Deposition of COOPER, G.; Vol. 7; Dated 05/03/84 A0084 Oral Deposition of COOPER, G.; Vol. 8; Dated 05/08/84 A0085 Oral Deposition of COOPER, G.; Vol.1; Dated l

04/23/85 A0086 j Oral Deposition of COOPER, G.; Vol. 2; Dated 1 i

04/24/85 i A0087 i

! Oral Deposition of CORCORAN, R.; Vol.1; Dated 12/05/83 A0088 Oral Deposition of CORCORAN, R.; Vol. 2; Dated 12/06/83 A0089 i Oral Deposition of COSCIA, G.; Vol.1; Dated 09/13/84 A0090 Oral Deposition of COSCIA, G.; Vol. 2; Dated

< 10/30/84 l

h Appendix A Document Number Document Title kbb9[ brak bepbsktkon bf bRkkb, b[; Ybk [; bated 02/22/84 A0092 Oral Deposition of CRANE, C.L.; Vol.1; Dated og , 10/27/83 A0093 Oral Deposition of CRANE, C.L.; Vol. 2; Dated 05/0'1/84 A0094 Oral Deposition of CRANE, C.L.; Vol. 3; Dated 05/10/84 A0095 Oral Deposition of CRANE, C.L.; Vol. 4; Dated 05/11/84 A0096 Oral Deposition of CRANE, C.L.; Vol.1; Dated 10/10/84 A0097 Oral Deposition of ENGEN, R. (Russell /Engen); Vol.

1; Dated 04/30/84 A0098 Gral Deposition of ENGEN, R. (Russtil/Engen); Vol.

2; Dated 05/01/84

-A0099 Oral Deposition of ENGEN, R. (Russell /Engen); Vol.

3; Dated 05/02/84 '

A0100 Oral Deposition of ENGEN, R. (Russell /Er gen); Vol.

4; Dated 05/03/84 A0101 Oral Deposition of ENGLISH, L.; Vol.1; Dated 03/25/85 A0102 Oral Deposition of ENGLISH, L.; Vol. 2: Dated 04/01/85 A0103 Oral Deposition of ENGLISH, L.; Vol. 3; Dated 04/16/65 t

A0104 Oral Deposition of ENGLISH, L.; Vol. 4; Dated 04/30/85 ,

A0105 Oral Deposition of FAWCETT, R.; Vol. 1; Dated '

04/30/84 A- 7 t 1/21/86 .

y t e  : ,e u w - -- -

i l

l Appendix A Document Number Document Title  !

kbkb6 brak beposktkbn of FkWCEkh, 5 $ ok 2$ bated I 05/01/84 A0107 Oral Deposition of FAWCETT, R.; Vol. 3; Dated 05/02/84 A0108 Oral Deposition of FAWCETT, R.; Vol. 4; Dated 05/03/84 A0109 Oral De,osition of FAWCETT, R.; Vol. 5; Dated 12/18/84 A0110 Oral Deposition of FAWCETT, R.; Vol. 6; Dated 12/19/84 A0111 Oral Deposition of FAWCETT, R.; Vol. 7; Dated 12/20/84 A0112 Oral Deposition of FISHER, G.; Vol.1; Dated 11/01/83 A0113 Urai Deposition of FISHER, G.; Vol. 2; Dated 11/02/83 A0114 Oral Deposition of FISHER, G.; Vol. 3; Dated 11/03/S3 A0115 Oral Deposition of FISHER, G.; Vol. 4; Dated 11/04/83 '

A0116 Oral Deposition of FISHER, G.; Vol. 5; Dated 11/07/83 A0117 Oral Deposition of FISHER, G.; Vol. 6; Dated 11/08/83 A0118 Oral Deposition of FISHER, G.; Vol. 7; Dated

{-

11/09/83 A0119 Oral Deposition of FISHER, G.; Vol. 8; Dated 11/10/83 A0120 Oral Deposition of FISHER, G.; Vol. 9; Dated 11/11/83 t

A- 8 1/21/86  ;

l l

Appendix A Document Number Document Title A0121 Oral Deposition of FISHER, G.; Vol. 1; Dated 09/24/84 (Relating to P.O. 6010; Deposition actually taken 09/25/84)

A0122 Oral Deposition of FISHER, G.; Vol.1; Dated 09/25/84 (Relating to P.O. 4012)

A0123 Oral Deposition of FLIPPO, J.; Vol.1; Dated 01/21/85 A0124 Oral Deposition of FLIPPO, J.; Vol. 2; Dated 01/22/85 A0125 Oral Deposition of FLIPPO, J.; Vol. 3; Dated 01/23/85 A0126 Oral Deposition of FLIPPO, J.; Vol. 4; Dated '

01/24/85 A0127 Oral Deposition of FRAZAR, R.; Vol.1; Dated 11/29/83 A0128 Oral Deposition of FRAZAR, R.; Vol. 2; Dated 11/30/83 AC129 Oral Deposition of FRAZAR, R.; Vol. 3; Dated 12/01/83 A0130 Oral Deposition of FRAZAR, W.; Vol. 4; Dated 02/07/84 A0131 Oral Deposition of FRAZAR, R.; Vol. 5; Dated 02/08/84 A0132 Oral Deposition of FRAZAR, R.; Vol. 6; Dated 02/09/84 A0133 Oral Deposition of FULGHUM, R.; Vol.1; Dated 02/21/84 A0134 Oral Deposition of FULGHUM, R.; Vol. 2; Dated 02/22/84 A0135 Oral Deposition of FULGHUM, R.; Vol. 3; Dated 06/26/84 A- 9 1/21/86

i Appendix A Document Number Document Title A0136 Oral Deposition of FULGHUM, R.; Vol. 4; Dated 06/27/84 A0137 Oral Deposition of FULGHUM, R.; Vol. 5; Dated 06/28/84 A0138 Oral Deposition of FULGHUM, R.; Vol. 6; Dated 06/29/84 A0139 Oral Deposition of GAMON, T.; Vol.1; Dated 03/13/84 '

A0140 Oral Deposition of GAMON, T.; Vol. 2; Dated 03/14/84 A0141 Oral Daposition of GEURTS, J.; Vol.1; Dated 04/04/84

\

A0142 Oral Deposition of GEURTS, J.; Vol. 2; Dated 07/16/84  ;

A0143 Oral Deposition of GODSEY, T.; Vol.1; Dated i

12/12/84 A0144 Oral Deposition of GOLDBERG, J.; Vol.1; Dated 07/28/83 A0145 Oral Deposition of GOLD 8 ERG, J.; Vol. 2; Dated 11/28/83 A0146 Oral Deposition of GRANGER, A.; Vol.1; Dated

~

01/05/84 A0147 Oral Deposition of GRANGER, A.; Vol. 2; Dated 01/06/84 A0148 Oral Deposition of GRANGER, A.; Vol.1; Dated 07/17/84 A0149 Oral Deposition of GRANGER, A.; Vol. 2; Dated 07/18/84 A0150 Oral Deposition of GRANGER, A.; Vol. 3; Dated 07/19/84 A - 10 1/21/86 0

I

(

Appendix A Dcts.7 ant Nusw iv- Document Title A0151 Gral Deposition of GRAY, J.D.; Vol.1; Dated 41/11/85 40151 Oral Deposition of GRAY, J.D.; Vol. 2; Dated .

02/13/85 A0153 Oral Deposition of GREENE, W.; Vol.1; Dated 08/20/84 A0154 Oral Deposition of GREENE, W.; Vol. 2; Dated 08/21/84 A0155 Oral Deposition of GREENE, W.; Vol. 3; Dated 11/26/84 A0156 Oral Deposition of GREENE, W.; Vol. 4; Dated 11/27/84 A0157 Oral Deposition of GREENE, W.; Vol. 5; Dated 02/06/85 A0158 Oral Deposition of GREENE, W.; Vol. 6; Dated t

02/07/85 A0159 Oral Deposition of GRIFFIN, G.; Vol.1; Dated 01/14/85 A0160 Oral Deposition of GRIFFIN, G.; Vol. 2; Dated 01/15/85 A0161 Oral Deposition of GRIFFIN, G.; Vol. 3; Dated 01/16/85 A0162 Oral Deposition of GRIFFIN, G.; Vol. 4; Dated 01/18/85 ,

A0163 Oral Deposition of GRIMES, J.; Vol.1; Dated 02/06/84 A0164 Oral Depositior. of GRIMES, J.; Vol. 2; Dated 02/07/84 A0165 Oral Deposition of GRIMES, J.; Vol. 3; Dated 02/08/84 A - 11

, 1/21/86

Appendix A Document Number Document Title A0166 Oral Deposition of GRIMES, J.; Vol. 4; Dated 02/09/84 A0167 Oral Deposition of GRIMES, J.; Vol. 5; Dated 03/06/84 A0168 Oral Deposition of GRIMES, J.; Vol. 6; Dated 03/07/84 A0169 Oral Deposition of GRIMES, J.; Vol. 7; Dated 03/08/84 A0170 Oral Deposition of GRIMES, J.; Vol. 8; Dated 03/09/84 A0171 Oral Deposition of GRIMES, J.

(Cooper / Jordan / Grimes); Vol.1; Dated 06/26/84 A0172 Oral Deposition of GRIMES, J.

(Cooper / Jordan / Grimes); Vol. 2; Dated 06/27/84 A0173 Oral Deposition of GRIMES, J.

(Cooper / Jordan / Grimes); Vol. 3; Dated 06/28/84 A0174 Oral Deposition of GRIMES, J.

(Cooper / Jordan / Grimes); Vol. 4; Dated 06/29/84 A0175 Oral Deposition of GRIMES, J.

(Cooper / Jordan / Grimes); Vol. 5; Dated 07/17/84 A0176 Oral Deposition of GRIMES, J.

1 (Cooper / Jordan / Grimes); Vol. 6; Dated 07/18/84 A0177 Oral Deposition of GRIMES, J.

, (Cooper / Jordan / Grimes); Vol. 7; Dated 07/19/84 A0178 Oral Deposition of GRIMES, J.

(Cooper / Jordan / Grimes); Vol. 8; Dated 07/26/84 A0179 Oral Deposition of GRIMES, J.; Vol.1; Dated i 08/22/84 i i

A0180 Oral Deposition of GRIMES, J.; Vol.1; Dated l 09/24/84 (Relating to P.O. 6005)

A - 12 1/21/86 i

Appendix A Document Number Document Title A0181 Oral Deposition of GRIMES, J.; Vol.1; Dated

, 09/24/84 (Relating to P.O. 4015) i A0182 Oral Deposition of GROTE, S.; Vol.1; Dated 11/30/83 A0183 Oral Deposition of GROTE, S.; Vol. 2; Dated 11/30/83 A0184 Oral Deposition of GROTE, S.; Vol. 3; Dated 09/10/84 A0185 Oral Deposition of GROTE, S.; Vol. 4; Dated 09/11/84 A0186 Oral Deposition of GROTE, S.; Vol. 5; Dated 09/12/84 A0187 Oral Deposition of GROTE, S.; Vol. 6; Dated 09/13/84 A0188 Oral Deposition of HANEIKO, J.; Vol.1; Dated 07/31/84 A0189 Oral Deposition of HANEIKO, J.; Vol. 2; Dated 08/01/84 i A0190 Oral Deposition of HANEIKO, J.; Vol. 3; Dated 08/17/84 A0191

Oral Deposition of HANKS, R.; Vol.1; Dated 04/23/84 A0192 Oral Deposition of HANKS, R.; Vol. 2; Dated 04/24/84 l A0193 Oral Deposition of HANKS, R.; Vol. 3; Dated 05/16/84 A0194 Oral Deposition of HANKS, R.; Vol. 4; Dated 05/17/84 1

A0195

' Oral Deposition of HANKS, R.; Vol. 5; Dated 05/18/84 A - 13 i 1/21/86 ,

t

(

-m. , _ . < _ - - - - - - - . ~ , -

-.r--.---, - --...# -,,--- ,,. -- --. , - -e

Appendix A Document Number Document Title A0196 Oral Deposition of HA41KS, R.; Vol.1; Dated 10/08/84 (Relating to P.O. 4011)

A0197 Oral Deposition of HANKS, R.; Vol.1; Dated 10/08/84 (Relating to P.O. 6024)

A0198 Oral Deposition of HANKS, R.; Vol.1; Dated 04/15/85 A0199 Oral Deposition of HANKS, R.; Vol. 2; Dated 04/16/85 A0200 Oral Deposition of HANKS, R.; Vol. 3; Dated 04/17/85 ,

A0201 Oral Deposition of HANSON, J.; Vol.1; Dated 01/16/85 A0202 Oral Deposition of HANSON, J.; Vol. 2; Dated 01/17/85 A0203 Oral Deposition of HANSON, J.; Vol. 3; Dated 01/18/85 A0204 Oral Deposition of HARDT, M.; Vol.1; Dated 02/08/84 A0205 Oral Deposition of HARDT, M.; Vol. 2; Dated 02/09/84 A0206 Oral Deposition of HARDT, M.; Vol. 3; Dated 08/27/84 A0207 Oral Deposition of HARDT, M.; Vol. 4; Dated 08/28/84 A0208 Oral Deposition of HARDT, M.; Vol. 5; Dated -

08/29/84

, A0209 Oral Deposition of HARDT, M.; Vol. 6; Dated 08/30/84' A0210 Oral Deposition of HARDT, M.; Vol. 7; Dated 08/31/84 A - 14 1/21/86 4 e i

Appendix A Document

.""$$'# . .................SUguggnt]1{1e A0211 Oral Deposition of HARDT, M.; Vol. 8; Dated 10/01/84 1

A0212 Oral Deposition of HARDT, M.; Vol. 9; Dated 10/02/84 A0213 Oral Deposition of HARDT, M.; Vol.10; Dated 10/03/84 A0214 Oral Deposition of HARRISON, A.; Vol.1; Dated 11/07/84 A0215 Oral Deposition of HARRISON, A.; Vol. 2; Dated 11/08/84 A0216 Oral Deposition of HARRISON, A.; Vol. 3; Dated 11/09/84 A0217 Oral Deposition of HARRISON, A.; Vol. 4; Dated 11/28/84 A0218 Oral Deposition of HARRISON, A.; Vol. 5; Dated 11/29/84 A0219 Oral Deposition of HARRISON, A.; Vol. 6; Dated 11/30/84

, A0220 Oral Deposition of HAWKS, J.; Vol.1; Dated

10/18/83 ,

t A0221 Oral Deposition of HAWKS, J.; Vol. 2; Dated 10/19/83 A0222 Oral Deposition of HAWKS, J.; Vol. 3; Dated t 10/20/83 .

{

A0223 Oral Deposition of HAWKS, J.; Vol. 4; Dated 02/13/84 A0224 Oral Deposition of HERNANDEZ, R.; Vol.1; Dated 06/19/84 A0225 Oral Deposition of HERNANDEZ, R.; Vol. 2; Dated 06/20/84 A - 15 1/21/86 J

l

._ _ ~ -- -

Appendix A Document flumber Document Title A0226 ...................................................

Oral Deposition of HERNANDEZ, R.; Vol. 3; Dated 07/24/84 i

A0227 Oral Deposition of HERNANDEZ, R.; Vol. 4; Dated 07/25/84 A0228 Oral Deposition of HERNANDEZ, R.; Vol. 5; Dated 07/26/84 A0229 Oral Deposition of HERNANDEZ, R.; Vol. 6; Dated 07/27/84 (

i A0230 Oral Deposition of HILLAKER, J.; Vol.1; Dated h 06/18/84 A0231 Oral Deposition of HILLAKER, J.; Vol. 2; Dated 06/19/84 A0232 Oral Deposition of HILLAKER, J.; Vol. 3; Dated 06/20/84 A0233 Oral Deposition of HILLAKER, J.; Vol. 4; Dated 06/21/84 A0234 Oral Deposition of HOE, R.; Vol. 1; Dated 06/14/84 A0235 Oral Deposition of H0E, R.; Vol. 2; Dated 06/15/84 A0236 Oral Deposition of HOE, R.; Vol. 3; Dated 08/17/84 A0237 Oral Deposition of HOE, R.; Vol. 4; Dated 08/18/84 A0238 Oral Deposition of HOE, R.; Vol. 5; Dated 08/19/84 A0239 Oral Deposition of HOE, R.; Vol. 6; Dated 03/12/85 A0240 Oral Deposition of HOE, R.; Vol. 7; Dated 03/13/85 A0241 Oral Deposition of HOE, R.; Vol. 8; Dated 03/14/85 A0242 Oral Deposition of HOE, R.; Vol. 9; Dated 03/15/85 A0243 Oral Deposition of H0RRIGAN, L.; Vol. I; Dated 01/31/85 A - 16 1/21/86

s Appendix A I i

Document Number Document Title kb24k brak bepositkon of HbWELL, b$$ Vbk k$ bhted 01/31/84 A0245 Oral Deposition of HOWELL, G ; Vol. 2; Dated 01/31/84 A0246 Oral Deposition of JACKSON, J.; Vol.1; Dated 1 01/10/84 i

A0247 Oral Deposition of JACKSON, J.; Vol. 2; Dated'  !

01/11/84 A0248 Oral Deposition of JACKSON, J.; Vol. 3; Dated 01/12/84 A0249 Oral Deposition of JACKSON, J.; Vol. 4; Dated 04/23/85 i

A0250 Oral Deposition of JACKSON, J.; Vol. 5; Dated 04/24/85 A0251 Oral Deposition of JACKSON, J.; Vol. 6;. Dated 04/25/85 A0252 Oral Deposition of JAUNAL, G.; Vol.1; Dated 07/24/84 A0253 Oral Deposition of JAUNAL, G.; Vol.1; Dated 10/16/84 A0254 Oral Deposition of JAUNAL, G.; Vol. 2; Dated 11/02/84 i A0255 Oral Deposition of JONES, C.R.; Vol.1; Dated 04/04/84 A0256 Oral Deposition of JCNES, C.R.; Vol. 2; Dated 04/05/84 1 A0257 Oral Deposition of JONES, C.R.; Vol. 3; Dated l 04/06/84 l.

1 A0258 Oral Deposition of JONES, C.R.; Vol. 4; Dated 05/09/84 A - 17 1/21/86

, i

)

l

Appendix A '

Document Number Document Title kb2b9 brak beposktkon of bbNES [ b )$ lo5 b$ bated 05/10/84 A0260 Oral Deposition of JONES, C.R.; Vol. 6; Dated '

05/31/84 .

A0261 Oral Deposition of JONES, C.R.; Vol. 7; Dated 06/01/84 A0262 Oral Deposition of JONES, C.R.; Vol. 8; Dated 06/04/84 {

l A0263 Oral Deposition of JONES, C.R.; Vol. 9; Dated 06/05/84 A0264 Oral Deposition of JONES, C.R.; Vol.10; Dated i

06/07/84 A0265 Oral Deposition of JONES, C.R.; Vol.11; Dated 06/08/84 A0266 Oral Deposition of JONES, R.; Vol.1; Dated 03/10/85 A0257 Oral Deposition of JORDAN, P.S.; Vol.1; Dated 11/01/83 A0268 Oral Deposition of JORDAN, P.S.; Vol. 2; Dated 11/02/83 A0269 Oral Deposition of JORDAN, P.S.; Vol. 3; Dated 11/03/83 A0270 Oral Deposition of JORDAN, P.S.; Vol. 4; Dated 11/04/83 A0271 Oral Deposition of JORDAN, P.S.; Vol. 5; Dated 11/21/83 0 A0272 Oral Deposition of JORDAN, P.S.; Vol. 6; Dated 1 11/22/83 A0273 Oral Deposition of JORDAN, P.S.; Vol. 7; Dated 11/23/83 A - 18 1/21/86

Appendix A Document Number Document Title kb27k braibepositionbfbbRbN P$S$$ lbk b$ bathd 12/06/83 A0275 Oral Deposition of JORDAN, P.S.; Vol. 9; Dated 12/07/83 A0276 Oral Deposition of JORDAN, P.S.; Vol.10; Dated 12/08/83 A0277 Oral Deposition of JORDAN, P.S.

(Jordan /Saltarelli); Vol.1; Dated 05/08/84 l 1

A0278 Oral Deposition of JORDAN, P.S. ,

(Jordan /Saltarelli); Vol. 2; Dated 05/09/84 t A0279 Oral Deposition of JORDAN, P.S.; Vol.11; Dated 05/22/84 A0280 i Oral Deposition of JORDAN, P.S.; Vol.12; Dated 05/23/84 l A0281 Oral Deposition of JORDAN, P.S.; Vol.1; Dated

' 01/31/85 A0282 Oral Deposition of JORDAN, P.S.; Vol. 2; Dated 02/01/85 A0283 Oral Deposition of JORDAN, T.J.; Vol.1; Dated 03/04/85 A0284 Oral Deposition of JORDAN, T.J.; Vol. 2; Dated 03/05/85 A0285 Oral Deposition of JORDAN, T.J.; Vol. 3; Dated 03/06/85 A0286 Oral Deposition of JORDAN, T.J.; Vol. 4; Dated 03/07/85 A0287 Oral Deposition of JORDAN, T.J.; Vol. 5; Dated 03/08/85 A0288 Oral Deposition of KEFAUVER, R.; Vol.1; Dated 12/11/84 A - 19 1/21/86

Appendix A Document Number Document Title kbhb9 brakbepsktko [f Ehd$hokk$ bate [bhhk4/bk A0290 Oral Deposition of KEY, H.; Vol. 2; Dated 02/15/84 A0291 Oral Deposition of KEY, H.; Vol. 3; Dated 02/16/84 A0292 Oral Deposition of KEY, H.; Vol. 4; Dated 02/17/84 A0293 Oral Deposition of KEY, H.; Vol. 5; Dated 03/06/84 A0294 Oral Deposition of KEY, H.; Vol. 6; Dated 03/07/84 A0295 Oral Deposition of KEY, H.; Vol. 7; Dated 03/08/84 A0296 Oral Deposition of KEY, H.; Vol. 8; Dated 04/11/84 A0297 Oral Deposition of KEY, H.; Vol. 9; Dated 04/12/84 i A0298 Oral Deposition of KEY, H.; Vol. 10; Dated 04/13/84 A0299 Oral Deposition of KEY, H.; Vol.11.; Dated 05/30/84 A0300 Oral Deposition of KEY, H.; Vol. 12; Dated 05/31/84 A0301 Oral Deposition of KEY, H.; Vol. 13; Dated 06/01/84 A0302 Oral Deposition of KEY, H.; Vol. 14; Dated 07/31/84 A0303 Oral Deposition of KEY, H.; Vol.15; Dated 08/01/84 A0304 Oral Deposition of KEY, H.; Vol.16; Dated 08/02/84 A0305 Oral Deposition of KEY, H.; Vol.17; Dated 10/31/84 A0306 Oral Deposition of KNAPP, F.; Vol.1; Dated 05/08/84 A0307 Oral Deposition of KNAPP, F.; Vol. 2; Dated 05/09/84 A0308 Oral Deposition of KNAPP, F.; Vol. 3; Dated 05/10/84 A0309 Oral Deposition of KNAPP, F.; Vol. 4; Dated 08/09/84

, A - 20 1/21/86 f

Appendix A Document Number Document Title kb3kb brak beposkthbn bf Kh PP F$$ Vo5 5; bated 08/10/84 A0311 Oral Deposition of KOHLER, L.R.

(Kohler/Wawrzeniak); Vol.1; Dated 06/18/84 A0312 Oral Deposition of KOHLER, L.R.

(Kohler/Wawrzentak); Vol. 2; Dated 06/19/84 A0313 Oral Deposition of KOHLER, L.R.

(Kohler/Wawrzeniak); Vol. 3; Dated 06/20/84 t A0314 Oral Deposition of K0 PAL, D.; Vol.1; Dated 07/18/84 A0315 Oral Deposition of LANDRY, K.; Vol.1; Dated .

09/04/84 A0316 Oral Deposition of LANDRY, K.; Vol. 2; Dated 09/05/84 A0317 Oral Deposition of LANDRY, K.; Vol. 3; Dated 09/06/84 A0318 Oral Deposition of LANDRY, K.; Vol. 4; Dated 09/07/84 A0319  !

Oral Deposition of LEASBURG, R.; Vol.1; Dated 06/06/84 A0320 Oral Deposition of LEASBURG, R.; Vol. 2; Dated 07/02/84 A0321 Oral Deposition of LEASBURG, R.; Vol. 3; Dated 1 07/03/84 A0322 Oral Deposition of LE8LANC, J.; Vol.1; Dated 07/12/84 A0323 Oral Deposition of LEE, J. (Jordan / Lee); Vol.1-  !

Dated 08/07/84  !

A0324 Oral Deposition of LEE, J. (Jordan / Lee); Vol. 2; Dated 08/08/84 A - 21

,q 1/21/86

l Appendix A Document Number Document Title A0325 Oral Deposition of LEE, J. (Jordan / Lee); Vol. 3; Dated 08/09/84 A0326 Oral Deposition of LEE, J. (Jordan / Lee); Vol. 4; Dated 08/10/84 A0327 Oral Deposition of LENTZ, J.; Vol.1; Dated 11/06/84 A0328 Oral Deposition of LENTZ, J.; Vol. 2; Dated 11/07/84 A0329 Oral Deposition of LENTZ, J.; Vol. 3; Dated 12/27/84  !

A0330 Oral Deposition of LESCHBER, E.; Vol.1; Dated 03/19/84 A0331 Oral Deposition of LESCHBER, E.; Vol. 2; Dated 03/20/84 A0332 Oral Deposition of LESCHBER, E.; Vol. 3; Dated 03/21/84 A0333 Oral Deposition of LESCHBER, E.; Vol. 4; Dated 03/22/84 A0334 Oral Deposition of LESCHBER, E.; Vol. 5; Dated 03/23/84 A0335 Oral Deposition of LEWIS, E.; Vol.1; Dated 07/24/84 A0336 Oral Deposition of LEWIS, E.; Vol. 2; Dated 07/25/84 A0337 Oral Deposition of LEWIS, E.; Vol. 3; Dated 07/26/84 A0338 Oral Deposition of LOGAN, T.; Vol.1; Dated 01/24/84 A0339 Oral Deposition of LOGAN, T.; Vol. 2; Dated 07/11/84 A - 22 1/21/86 i

)

1 Appendix A l Document Number Document Title kb34b brak beposktkon ofibbkN T$$Voi 3$ bated 07/12/84 j A0341 Oral Deposition of LOGAN, T.; Vol. 4; Dated 03/26/85 A0342 Oral Deposition of LOGAN, T.; Vol. 5; Dated 03/27/85 A0343 Oral Deposition of LONG, D.; Vol. 1; Dated 08/08/84 A0344 Oral Deposition of LONG, D.; Vol. 2; Dated 08/09/84 A0345 Oral Deposition of LONG, D.; Vol.1; Dated 08/16/84 A0346 Oral Deposition of LONG, D.; Vol. 1; Dated 12/12/84 A0347 Oral Decosition of LONG, D.; Vol. 2; Dated 12/13/84 l l

A0348 Oral Deposition of LONG, D.; Vol. 3; Dated 12/14/84 j A0349 Oral Deposition of LUDWIG, M.; Vol. 1; Dated 03/27/85 A0350 Oral Deposition of LUDWIG, M.; Vol. 2; Dated 03/28/85 l

A0351 Oral Deposition of LUKE, M.; Vol.1; Dated 10/10/83 A0352 Oral Deposition of LUKE, M.; Vol. 2; Dated 10/11/83 l

A0353 Oral Deposition of LUKE, M.; Vol. 3; Dated 10/12/83 A0354 Oral Deposition of LUKE, M.; Vol. 4; Dated 10/31/83 A0355 Oral Deposition of LUKE, M.; Vol. 5; Dated 11/01/83 A0356 Oral Deposition of LUKE, M.; Vol. 6; Dated 11/02/83 A0357 Oral Deposition of LUKE, M.; Vol. 7; Dated 11/03/83 A0358 Oral Deposition of LUKE, M.; Vol. 8; Dated 11/04/83 A0359 Oral Deposition of LUKE, M.; Vol. 9; Dated 12/01/83 A - 23 1/21/86 l

Appendix A Document Number Document Title kb3bb brak beposktkon of LbKh, M$$ Vbi$ [b$ bated 12/02/83 A0361 Oral Deposition of LUKE, M.; Vol.11; Dated 12/15/83 A0362 Oral Deposition of LUKE, M.; Vol.12; Dated 01/09/84 A0363 Oral Deposition of LUKE, M.; Vol.13; Dated 01/10/84 A0364 Oral Deposition of LUKE, M.; Vol.14; Dated 01/11/84 A0365 Oral Deposition of LUKE, M.; Vol.15; Dated 01/12/84 A0366 Oral Deposition of LUKE, M.; Vol.16; Dated 01/30/84 A0367 Oral Deposition of LUKE, M.; Vol.17; Dated 01/31/84 A0368 Oral Deposition of LUKE, M.; Vol.18; Dated 02/01/84 '

A0369 Oral reposition of LUKE, M.; Vol.19; Dated 02/0!/84 A0370 Oral Deposition of LUKE, M.; Vol. 20; Dated 02/03/8A A0371 Oral Deposition of LUKE, M.; Vol. 21; Dated 08/21/84 A0372 Oral Deposition of LUKE, M.; Vol. 22; Dated 08/22/84 A0373 Oral Deposition of LUKE, M.; Vol. 23; Dated 08/23/84 A0374 Oral Deposition of MANASCO, G.; Vol.1; Dated 12/04/84 A - 24 1/21/86 1

.n v - - - - - - , . - - - - - - ~ , , - - . , + , , , , , - . , ,r-.m , - - ,- -r

~:

g Appendix A Document Number Document Title A0375 Oral Deposition of MARSHALL, G.; Vol. 1; Dated 03/06/84 A0376 Oral Deposition of MARSHALL, G.; Vol. 2; Dated

~

03/07/84 A0377 Oral Deposition of MARSHALL, G.; Vol. 3; Dated 03/08/84 A0378 Oral Deposition of McCLURE, C.; Vol.1; Dated 09/04/84 A0379 Oral Deposition of McCLURE, C.; Vol. 2; Dated 09/05/84 A0380 Oral Deposition of McCLURE, C.; Vol.1; Dated 09/06/84 A0381 Oral Deposition of McCLURE, C.; Vol. 2; Dated 09/06/84 A0382 Oral Deposition of McCLURE, C.; Vol. 3; Dated 09/07/84 A0383 Oral Deposition of McCLURE, C.; Vol. 3; Dated 01/17/85 A0384 Oral Deposition of McCLURE, C.; Vol. 4; Dated 01/18/85 A0385 Oral Deposition of McDANIEL, R.; Vol.1; Dated 02/28/84 A0386 Oral Deposition of McDANIEL, R.; Vol. 2; Dated 02/29/84 1 A0387 Oral Deposition of McPHERSON, C.; Vol.1; Dated 06/05/84 A0388 Oral Deposition of MENGER, W.; Vol.1; Dated 09/11/84 A0389 Oral Deposition of MENGER, W.; Vol. 2; Dated i

09/12/84 1

A - 25 1/21/86 I

l Appendix A Document  !

Number Document Title A0390 Oral Deposition of MENGER, W.; Vol. 3; Dated 09/13/84 i

A0391 Oral Deposition of MENGER, W.; Vol. 4; Dated 09/14/84  !

A0392 Oral Deposition of MENGER, W.; Vol. 5; Dated 05/07/85 l

A0393 Oral Deposition of MENGER, W.; Vol. 6; Dated 05/09/85 A0394 l t

1 Oral Deposition of MENGER, W.; Vol. 7; Dated 05/10/85 i i

A0395 Oral Deposition of MESSER, C.; Vol.1; Dated 11/14-15/84 A0396 Oral Deposition of MEYER, M.; Vol.1; Dated 08/02/83 i A0397 Oral Deposition of MEYER, M.; Vol. 2; Dated 08/02/83 A0398 Oral Deposition of MEYER, M.; Vol. 3; Dated 08/03/83

, A0399 Oral Deposition of MEYER, M.; Vol. 4; Dated 08/04/83 A0400 Oral Deposition of MEYER, M.; Vol. 5; Dated I

08/04/83 A0401 Oral Deposition of MEYER, M.; Vol. 6; Dated 08/05/83 A0402 Oral Deposition of MEYER, M.; Vol. 6; Dated 09/19/83 A0403 Oral Deposition of MEYER, M.; Vol. 7; Dated 09/20/83 A0404 Oral Deposition of MEYER, M.; Vol. 8; Dated 09/21/83 1

i A - 26 1/21/86

l l

l l

Appendix A Document Number Document Title kb4bh brakbhpbsktkonbbbkhhR h ; hok 9; bathd 09/22/83 A0406 Oral Deposition of MEYER, M.; Vol.- 10; Dated 09/22/83  !

A0407 Oral Deposition of MEYER, M.; Vol.11; Dated 09/23/83 1 A0408 Oral Dero 2ition of MEYER, M.; Vol.12; Dated 10/24/L .

I A0409 Oral Deposition of MEYER, M.; Vol.13; Dated 10/25/83 1 A0410 Oral Deposition of MEYER, M.; Vol.14; Dated 10/26/83 i A0411 Oral Deposition of MEYER, M.; Vol. 15; Dated 10/26/83 A0412 Oral Deposition of MEYER, M.; Vol.16; Dated 10/27/83 A0413 Oral Deposition of MEYER, M.; Vol.17; Dated 10/28/83 A0414 Oral Deposition of MEYER, M.; Vol.18; Dated 11/14/83 A0415 Oral Deposition of MEYER, M.; Vol.19; Dated 11/15/83 A0416 Oral Deposition of MEYER, M.; Vol. 20; Dated 11/16/83 A0417 Oral Deposition of MEYER, M. (Heyer/ Lee); Vol.1; Dated 03/27/85 A0418 I Oral Deposition of MEYER, M. (Meyer/ Lee); Vol. 2; Dated 03/28/85 4

A0419  !

Oral Deposition of MEYER, M. (Meyer/ Lee); Vol. 3; Dated 03/29/85 '

A - 27 1

I 1/21/86 l

l

\

Appendix A Document Number Document Title kb4hb brak beposktko[bf .kkLLkh b$h oi$k$bateh 02/14/85 1 A0421 Oral Deposition of MITCHELL, B.; Vol.1; Dated  !

06/14/84 A0422 Oral Deposition of MITCHELL, B.; Vol. 2; Dated l 06/15/84 l A0423 Oral Deposition of MONROE, J.; Vol.1; Dated 08/29/83 i A0424 Oral Deposition of MONROE, J.; Vol. 2; Dated '

08/30/83 -

A0425 Oral Deposition of MONROE, J.; Vol. 3; Dated 10/24/83 A0426 Oral Deposition of MONROE, J.; Vol. 4; Dated 10/25/83 A0427 Oral Deposition of MONROE, J.; Vol. 5; Dated 10/28/83 i A0428 Oral Deposition of MOONEY, J.; Vol.1; Dated 04/16/84 A0429 Oral Deposition of MOONEY, J.; Vol. 2; Dated 04/17/84 A0430 Oral Deposition of MOONEY, J.; Vol. 3; Dated 04/18/84 A0431 Oral Deposition of MOONEY, J.; Vol. 4; Dated 04/19/84 A0432 Oral Deposition of MOORE, J.; Vol.1; Dated 01/17/84 A0433 Oral Deposition of MORGAN, W.; Vol.1; Dated 09/25/84 A0434 Oral Deposition of MORGAN, W.; Vol. 2; Dated 09/26/84 A - 28 1/21/86

Appendix A Document Num~er c Document Title kb4b5 braibepbsktkonbfibRbkN $3bk b bated 09/27/84 A0436 Oral Deposition of MORGAN, W.; Vol. 4; Dated 09/28/84 A0437 Oral Deposition of MORGAN, W.; Vol. 5; Dated 03/26/85 A0438 Oral Deposition of MORGAN, W.; Vol. 6; Dated 03/27/85 A0439 Oral Deposition of MORGAN, W.; Vol. 7; Dated 03/28/85 i

A0440 Oral Deposition of MORRIS, G.; Vol.1; Dated 1 05/07/84 -l A0441 Oral Deposition of MORRIS, G.; Vol. 2; Dated 05/08/84 A0442 Oral Deposition of MORRIS, G.; Vol. 3; Dated 05/n9/84 A0443 Oral Deposition of MORRIS, G.; Vol. 4; Dated 05/10/84 A0444 Oral Deposition of MORRIS, G.; Vol. 5; Dated 05/21/84 A0445 Oral Dep' :ition of MORRIS, G.; Vol. 6; Dated 05/22/8.

A0446 Oral Deposition of MORRIS, G.; Vol. 7; Dated 06/13/84 A0447 Oral Deposition of MORRIS, G.; Vol. 8; Dated 06/14/84 A0448 Oral Deposition of MORRIS, G.; Vol. 9; Dated 08/02/84 I

A0449 Oral Deposition of MORROW, I.; Vol.1; Dated 03/11/85 A - 29 1/21/86

Appendix A Document Number Document Title kb4hb brakbepositkonobMbhER [ ; Vok 1; bated 03/26/84 A0451 Oral Deposition of MOSER, J.; Vol. 2; Dated 03/27/84 A0452 Oral Deposition of MOSER, J.; Vol. 3; Dated 03/28/84 A0453 Oral Deposition of MOSER, J.; Vol. 4; Dated 03/29/84 A0454 Oral Deposition of MOSER, J.; Vol. 5; Dated 03/30/84 A0455 Oral Deposition of MUELLNER, F.; Vol. 1; Dated 11/28/83

)

A0456 Oral Deposition of MUELLNER, F.; Vol. 2; Dated 12/12-13/83 A0457 Oral Deposition of MUELLNER, F.; Vol. 3; Dated i

12/14/83 A0458 Oral Deposition of MUELLNER, F.; Vol. 4; Dated 12/15/83 A0459 Oral Deposition of MUELLNER. P. , 501. 5; Dated 12/29/83 A0460 Oral Deposition of MUNISTERI, J., Vol.1; Dated i

04/02/84 A0461 Oral Deposition of MUNISTERI, J.; Vol. 2; Dated 04/03/84 A0462 Oral Deposition of MUNISTERI, J.; Vol. 3; Dated 04/04/84 A0463 Oral Deposition of MUNISTERI, J.; Vol. 4; Dated 04/09/84 A0464 Oral Deposition of MUNISTERI, J.; Vol. 5; Dated 04/10/84 A - 30 .

1/21/86

Appendix A Document Number Document Title kb4b5 brak bepositkon of MbbkhTERk b$$ Vbk 6; bated 04/11/84 A0466 Oral Deposition of MUNISTERI, J.; Vol. 7; Dated 04/12/84 A0467 Oral Deposition of MUSCENTE, M.; Vol.1; Dated 05/24/84 A0468 Oral Deposition of MUSCENTE, M.; Vol. 2; Dated 05/25/84 A0469 Oral Deposition of NATARAJAN, T.; Vol.1; Dated 01/30/85 A0470 Oral Deposition of NEWTON, D.; Vol.1; Dated 08/03/84 A0471 Oral Deposition of NEWTON, D.; Vol. 2; Dated 08/06/84

! A0472 Oral Deposition of NEWTON, D.; Vol. 3; Dated i

08/07/84 A0473 Oral Deposition of NICHOLS, N.; Vol.1; Dated 10/11/84 A0474 Oral Deposition of O'BRIEN, F.; Vol.1; Dated 09/05/84 A0475 Oral Deposition of O'BRIEN, F.; Vol. 2; Dated 01/15/85 4'

A0476 Oral Deposition of OLVER, D.; Vol.1; Dated 11/28-29/83 A0477 Oral Deposition of OLVER, D.; Vol. 2; Dated 11/30/83 i

A0478 Oral Deposition of OL.VER, D.; Vol. 3; Dated 12/01/83 A0479 Oral Deposition of OLVER, D.; Vol. 4; Dated 12/02/83 A - 31 1/21/86

r Appendix A Document Number Document Title b4hb br$k beposition of blVhR, b $ Vbk h$ baked 12/08/83 A0481 Oral Deposition of OLVER, D.; Vol. 6; Dated 12/09/83 A0482 Oral Deposition of OLVER, D.; Vol. 7; Dated 01/16/84 A0483 Oral Deposition of OLVER, D.; Vol. 8; Dated 01/17/84 A0484 Oral Deposition of OLVER, D.; Vol. 9; Dated 01/19/84 A0485 Oral Deposition of OLVER, D.; Vol.10; Dated 01/20/84 A0486 Oral Deposition of OPREA, G.; Vol. 1; Dated 07/27/83 A0487 Oral Deposition of OPREA, G.; Vol. 2; Dated i 08/29/83 {

A0488 Oral Deposition of OPREA, G.; Vol. 3; Dated 12/05/83 ,

)

A0489 Oral Deposition of OPREA, G.; Vol. 4; Dated l 06/04/84 A0490 Oral Deposition of OPREA, G.; Vol. 5; Dated 06/05/84 A0491 Oral Deposition of OPREA, G.; Vol. 6; Dated 06/06/84 A0492 Oral Deposition of OPREA, G.; Vol. 7; Dated 06/07/84 A0493 Oral Deposition of OPREA, G.; Vol. 8; Dated i 06/08/84 A0494 Oral Deposition of OPREA, G.; Vol. 9; Dated 06/11/84  :

A - 32 1/21/86 1

Appendix A Document Number Document Title A0495 Oral Deposition of OPREA, G.; Vol.10; Dated 06/12/84 A0496 Oral Deposition of OPREA, G.; Vol. 11; Dated 06/18/84

' A0497 Oral Deposition of OPREA, G.; Vol.12; Dated 06/19/84 A0498 Oral Deposition of OPREA, G.; Vol.13; Dated 06/25/84 A0499 Oral Deposition of OPREA, G.; Vol.14; Dated 06/26/84 A0500 Oral Deposition of OPREA, G.; Vol.15; Dated 06/27/84 A0501 Oral Deposition of OPREA, G.; Vol.16; Dated 06/28/84 .

A0502 Oral Deposition of OPREA, G.; Vol.17; Dated 06/29/84 A0503 Oral Deposition of OPREA, G.; Vol.18; Dated 07/20/84 A0504 Oral Jeposition of OPREA, G.; Vol.19; Dated 07/24/84 i

A0505 Oral Deposition of OPREA, G.; Vol. 20; Dated 08/28/84 A0506 Oral Deposition of OPREA, G.; Vol. 21; Dated 08/29/84 I

A0507 Oral Deposition of OVERSTREET, H.; Vol.1; Dated 04/10/84 A0508 i Oral Deposition of OVERSTREET, H.; Vol. 2; Dated 04/11/84 A0509 Oral Deposition of OVERSTREET, H.; Vol. 3; Dated 04/12/84 i 1

I I

A - 33 1/21/86  !

i l

l

.) l i

1

Appendix A Document Number Document Title A0510 Oral Deposition of PAVLICEK, J.; Vol. 1; Dated 12/19/84 A0511 Oral Deposition of PAVLICEK, J.; Vol. 2; Dated 12/20/84 A0512 Oral Deposition of PAVLICEK, J.; Vol. 3; Dated 01/03/85 l A0513 i Oral Deposition of PETTERSSON, C.; Vol.1; Dated l 10/23/84am I A0514 Oral Deposition of PETTERSSON, C.; Vol.1; Dated 10/23/84pm A0515 Oral Deposition of PETTERSSON, C.; Vol. 2; Dated 10/24/84 A0516 Oral Deposition of PETTERSSON, C.; Vol. 3; Dated 10/25/84 A0517 Oral Deposition of PETTY, R.; Vol. 1; Dated  !

02/02/84 1 A0518 Oral Deposition of PETTY, R.; Vol. 2; Dated I 02/03/84 A0519 Oral Deposition of PETTY, R.; Vol. 3; Dated 03/08/84 i A0520 Oral Deposition of PEVERLEY, R.; Unnumbered; Dated 06/16/83am A0521 Oral Deposition of PEVERLEY, R.; Unnumbered; Dated 06/16/83pm .

l l

A0522 l Oral Deposition of PEVERLEY, R.; Vol. 2; Dated 1 03/28/84 A0523 Oral Deposition of PEVERLEY, R.; Vol. 3; Dated 03/29/84 A0524 I Oral Deposition of PEVERLEY, R.; Vol.1; Dated  !

08/14/84 A - 34 1/21/86 j

Appendix A Document Number Document Title kbbhh brakbepositkonof3hhhkLkhR$$hbk$h$ baked 08/15/84 '

A0526 Oral Deposition of PEVERLEY, R.; Vol. 3; Dated 08/16/84 ,

t A0527 Oral Deposition of PEVERLEY, R.; Vol. 4; Dated l 08/17/84  !

A0528 Oral Deposition of PEVERLEY, R.; Vol. 5; Dated 11/13/84 A0529 Oral Deposition of PEVERLEY, R.; Vol. 6; Dated I 11/14/84 l

! A0530 Oral Deposition of PEVERLEY, R.; Vol. 7; Dated 04/09/85 j l

A0531 Oral Deposition of PHELPS, J.; Vol.1; Dated 08/14/84 A0532 Oral Deposition of PHELPS, J.; Vol. 2; Dated i 08/15/84 A0533 Oral Deposition of PULLIN, A.D.; Vol. 1; Dated j 02/14/84 A0534 Oral Deposition of PULLIN, A.D.; Vol. 2; Dated 02/15/84 A0535 Oral Deposition of PU!LIN, A.D.; Vol. 3; Dated i

02/16/84 A0536 Oral Deposition of PULLIN, A.D.; Vol. 4; Dated 02/17/84 A0537 Oral Deposition of RASNICK, S.A.; Vol.1; Dated 04/29/85 A0538 Oral Deposition of RASNICK, S.A.; Vol. 2; Dated 04/30/85 A0539 Oral Deposition of RASNICK, S.A.; Vol. 3; Dated 05/01/85 A - 35 1/21/86 e

Appendix A Document Number Document Title A0540 ...................................................

Oral Deposition of REDER, R.E.; Vol.1; Dated 08/06/84 A0541 Oral Deposition of REDER, R.E.; Vol. 2; Dated 08/07/84 i A0542 Oral Deposition of REDER, R.E.; Vol. 3; Dated '

08/08/84 A0543 Oral Deposition of REDER, R.E.; Vol. 4; Dated l 08/09/84 A0544 Oral Deposition of REDER, R.E.; Vol. 5; Dated 08/10/84 A0545 Oral Deposition of REJCEK, M.; Vol.1; Dated 08/24/84 A0546 Oral Deposition of REJCEK, M.; Vol. 1; Dated 08/30/84 A0547 Oral Deposition of RICE, W.; Vol.1; Dated 05/29/84 A0548 Oral Deposition of RICE, W.; Vol. 2; Dated 05/30/84 A0549 Oral Deposition of RICE, W.; Vol. 3; Dated 05/31/84 A0550 Oral Deposition of RICE, W.; Vol. 4; Dated 06/01/84 A0551 Oral Deposition of RICHARDSON, E.; Vol. 1; Dated 11/01/83 A0552 Oral Deposition of RICHARDSON, E.; Vol. 2; Dated 11/02/83  !

A0553 Oral Deposition of RICHARDSON, E.; Vol. 3; Dated 11/11/83

^ A0554 Oral Deposition of RICHARDSON, E.; Vol.1; Dated 10/11/84

A0555 Oral Deposition of RIDDLE, E.; Vol.1; Dated 07/08/83 i

A - 36 1/21/86

Appendix A Document Number Document Title A0556 Oral Deposition of ROBERTS, J.; Vol.1; Dated 08/16/84 A0557 Oral Deposition of RODGERS, S.; Vol.1; Dated 08/16/84 A0558 Oral Deposition of RODGERS, S.; Vol. ?; Dated 08/17/84 A0559 Oral Deposition of ROGAN, S.; Vol.1; Dated 07/11/84 A0560 Oral Deposition of ROMEO, R.; Vol.1; Dated 05/29/84 A0561 Oral Deposition of ROMEO, R.; Vol. 2; Dated 05/30/84 A0562 Oral Deposition of ROMEO, R.; Vol. 3; Dated 05/31/84 A0563 Oral Deposition of ROMEO, R.; Vol. 4; Dated 06/01/84 A0564 Oral Deposition of ROMEO, R.; Vol. 5; Dated 08/29/84 l

A0565 Oral Deposition of ROSE, G.; Vol. 1; Dated 06/26/84 l

A0566 Oral Deposition of ROSE, G.; Vol. 2; Dated 06/27/84 A0567 Oral Deposition of ROSE, G.; Vol. 3; Dated 06/28/84 A0568 Oral Deposition of ROSE, G.; Vol. 4; Dated 06/29/84 A0569 Oral Deposition of RUSSELL, R.; Vol.1; Dated 04/18/84 A0570 Oral Deposition of RUSSELL, R.; Vol. 2; Dated 04/19/84 .

A0571 Oral Deposition of RUSSELL, R.; Vol. 3; Dated 04/20/84 A - 37 1/21/86 1

1 l

i

.- ~-, .--,--- . -,.- - _ . ~_ -.y-.._. . . _ . . . - - - - -

i l

l 1

Appendix A Document Number Document Title bbh2 brai beposktkon of RbhhklL R$$Voi 4$ bated 04/27/84 t A0573 Oral Deposition of SALTARELLI, E.; Vol.1; Dated 10/25/83 A0574 Oral Deposition of SALTARELLI, E.; Vol.1; Dated 07/16/84 A0575 Oral Deposition of SALTARELLI, E.; Vol. 2; Dated 07/17/84 A0576 Oral Deposition of SALTARELLI, E.; Vol. 3; Dated 07/18/84 i A0577 Oral Deposition of SALTARELLI, E.; Vol. 4; Dated 07/19/84 A0578 Oral Deposition of SALTARELLI, E.; Vol. 5; Dated i

07/20/84 A0579 Oral Deposition of SALTARELLI, E.; Vol.1; Dated 12/11/84 A0580 Oral Deposition of SALTARELLI, E.; Vol. 2; Dated 4

12/12/84 A0581 Oral Deposition of SALTARELLI, E.; Vol. 3; Dated 12/13/84 A0582 Oral Deposition of SALTARELL1, E.; Vol. 4; Dated 12/14/84 A0583 Oral Deposition of SALTARELLI, E.; Vol. 5; Dated 01/09/85 A0584 Oral Deposition of SALTARELLI, E.; Vol. 6; Dated 01/10/85 A0585 Oral Deposition of SCHAEFFER, S.C.; Vol.1; Dated 03/25/85 A0586 Oral Deposition of SCHAEFFER, S.C.; Vol. 2; Dated i

03/26/85 A - 38 1/21/86 i

- - - _ , _ _ . _ _ . , _ -._s____,y _

-.m_ . - ,_,_ ,,. , . - _~ _ -_ . ,.m -

Appredix A Document 4

Number Document Title kb5h7 brakbepsktko fhCHbEhEhERbk$$Vokkhbated 09/12/83 i

A0588 Oral Deposition of SCHOENEBERG, A.; Vol. 2; Dated l 09/13/83 '

A0589 Oral Deposition of SCHOENEBERG, A.; Vol.1; Dated 11/15/84 A0590 Oral Deposition of SCHOENEBERG, A.; Vol.1; Dated i

11/16/84 l A0591 Oral Deposition of SCHOENEBERG, A.; Vol. 2; Dated 11/30/84 (Relating to P.O. 4006)

A0592 Oral Deposition of SCHOENEBERG, A.; Vol. 2; Dated 11/30/84 (Relating to P.O. 4017) l A0593 Oral Deposition of SIANO, M.; Vol.1; Dated 01/30/85 A0594 Oral Deposition of SIGNORELLI, J.A.; Vol.1; Dated 01/27/84 A0595 Oral Deposition of SMITH, R.; Vol.1; Dated 10/31/84 A0596 Oral Deposition of SMITH, R.; Vol. 2; Dated 11/01/84 A0597 Oral Deposition of SPIRES, G.; Vol.1; Dated 09/11/84 A0598 Oral Deposition of STEINMANN, G.; Vol.1; Dated 01/10/85 A0599 Oral Deposition of STINSON, R.; Vol.1; Dated 07/17/84 .

l A0600 Oral Deposition of STINSON, R.; Vol. 2; Dated 07/18/84 4

A0601 Oral Deposition of STINSON, R.; Vol. 3; Dated 07/19/84 A - 39 1/21/86 I

l Appendix A Document Number Document Title kbbbh brak beposktkok of hTihhbh R$ Voi 4$ bated 07/20/84  ;

A0603 Oral Deposition of STINSON, R.; Vol. 5; Dated 04/16/85 {

l A0604 Oral Deposition of STINSON, R.; Vol. 6; Dated 04/17/85 ,

A0605 Oral Deposition of SUMPTER, J.; Vol.1; Dat i 02/07/84 ,

3 A0606 Oral Deposition of TOBIAS, R.; Vol. 1; Dated 03/06/84

)

A0607 Oral Deposition of TOBIAS, R.; Vol. 2; Dated 03/07/84  !

A0608 i Oral Deposition of TOBIAS, R.; Vol. 3; Dated 03/08/84 A0609 Oral Deposition of TOBIAS, R.; Vol. 4; Dated 03/09/84 i

A0610 Oral Deposition of TRAYLOR, R.; Vol. 1; Dated 02/08/84 A0611 Oral Deposition of TRAYLOR, R.; Vol. 2; Dated 02/09/84 A0612 Oral Deposition of TRAYLOR, R.; Vol. 3; Dated 02/10/84 A0613 Oral Deposition of TRAYLOR, R.; Vol. 4; Dated 01/08/85 A0614 Oral Deposition of TRAYLOR, R.; Vol. 5; Dated

, 01/09/85 A0615 Oral Deposition of TRAYLOR, R.; Vol. 6; Dated 01/10/85

A0616 Oral Deposition of TRAYLOR, R.; Vol. 7; Dated 01/11/85 A - 40 1/21/86

Appendix A Document Number Document Title kb6kh brak bepbskthbn bf hbRhER b hokk$ bated 11/01/84 A0618 Oral Deposition of TURNER, E.A.; Unnumbered; Dated 07/12/83 A0619 Oral Deposition of TURNER, E.A.; Vol. 2; Dated 04/25/84 '

A0620 Oral Deposition of TURNER, E.A.; Vol. 3; Dated 04/26/84 A0621 Oral Deposition of ULREY, R.; Vol.1; Dated 04/24/84 1

A0622 Oral Deposition of ULREY, R.; Vol. 2; Dated 04/25/84 A0623 Oral Deposition of ULREY, R.; Vol. 3; Dated 04/26/84 i

A0624 Oral Deposition of ULREY, R.; Vol. 4; Dated 08/22/84 A0625 Oral Daposition of ULREY, R.; Vol. E; Dated t 08/23/84 l A0626 Oral Deposition of UNDERWOOD, T.; Vol.1; Dated j 12/11/84 l

ACS27 Oral Deposition of VALENTINE, J.; Vol.1; Dated 03/15/84 i i

i A0628 Oral Depolition of VALENTINE, J.; Vol.1; Dated  !

08/14/84 1 A0629 Oral Deposition of VALENTINE, J.; Vol. 2; Dated 4

08/15/84 i

A0630 Oral Deposition of VALENTINE, J.; Vol. 3; Dated 08/16/84

A0631 Oral Deposition of VALENTINE, J.; Vol. 1; Dated 12/20/84 A - 41 1/21/86 i

j

1 l

l l

Appendix A

, Document i I

..IT!'[ .

U

.................IS3?!91.I!!I.I....................

A0532 Oral Deposition of VALENTINE, J.; Vol. 2; Dated 12/21/84 .

A0633 Oral Deposition of VESELKA, S.; Vol.1; Dated 12/12/83 A0634 Oral Deposition of VESELKA, S.; Vol. 2; Dated 12/13/83 A0635 Oral Deposition of VESELKA, S.; Vol. 3; Dated 12/19/83 A0636 Oral Deposition of VESELKA, S.; Vol. 4; Dated 12/20/83 L

A0637 Oral Deposition of VESELKA, S.; Vol. 5; Dated l 12/21/83 l A0638 Oral Deposition of VESELKA, S.; Vol.1; Dated 10/18/84 i

A0639 Oral Deposition of VESELKA, S.; Vol. 1; Dated 02/04/85 i i

A0640 Oral Deposition of VESELKA, S.; Vol. 2; Dated 02/05/85 A0641 Oral Deposition of VESELKA, S.; Vol. 3; Dated 02/06/85 l

A0642 Oral Deposition of VIACLOVSKY, S.; Vol. 1; Dated 05/15/84 A0643 Oral Deposition of VIACLOVSKY, S.; Vol. 2; Dated 05/16/84 A0644 Oral Deposition of VIACLOVSKY, S.; Vol. 3; Dated l 06/28/84 l

A0645 Oral Daposition of VIACLOVSKY, S.; Vol. 4; Dated l 06/29/84  !

i A0646 Oral Deposition of VURPILLAT, R.; Vol.1; Dated 05/01/84  !

A - 42 1/21/86 i

Appendix A Document Number Document Title kbh4h brak beposhthon of hbRPkLLkh R$$ Vck 2$ bated 05/02/84 A0648 Oral Deposition of VURPILLAT, R.; Vol. 3; Dated 06/12/84 A0649 Oral Deposition of VURPILLAT, R.; Vol. 4; Dated 06/13/84 A0650 Oral Deposition of WAHL, J.; Vol.1; Dated 01/09/85 A0651 Orcl Deposition of WALKER, P.; Vol.1; Dated 06/21/84 t AC652 Oral Deposition of WALKER, P.; Vol. 2; Dated 06/22/84  ;

AOC53 Oral Deposition of WAWRZENIAK, J.

(Wawrzeniak/ Jordan); Vol. 1; Dated 04/03/84 1

{

A0654 Oral Deposition of WAWRZENIAK, J.

l (Wawrzeniak/ Jordan); Vol. 2; Dated 04/04/84 A0655 Oral Deposition of WAWRZENIAK, J.

(Wawrzeniak/ Jordan); Vol. 3; Dated 04/05/84 A0056 Oral Deposition of WAWRZENIAK, J.

(Wawrzeniak/ Jordan); Vol. 4; Dated 04/06/84 A0657 Oral Deposition of WAWRZENIAK, J.; Vol. 1; Dated 06/05/84 A0658 i Oral Deposition of WAWRZENIAK, J.; Vol. 2; Dated l 05/06/84 A0659 Oral Deposition of WAWRZENIAK, J.; Vol. 3; Dated 06/07/84 A0660 Oral Deposition of WAWRZENIAK, J.; Vol. 4; Dated 06/08/84 A0661 Oral Deposition of WAWRZENIAK, J.

(Kohler/Wawrzeniak); Vol. 4; Dated 06/21/84 A - 43 1/21/86 1

Appendix A Document Number Document Title A0662 Oral Deposition of WAWRZENIAK, J.

(Kohler/Wawrzeniak); Vol. 5; Dated 06/22/84 A0663 Oral Deposition of WEATHERS, W.; Vol. 1; Dated 08/21/84 t

A0664 Oral Deposition of WEATHERS, W.; Vol. 2; Dated 08/22/84 A0665 Oral Deposition of WEATHERS, W.; Vol. 3; Dated 08/23/84 [

L.

A0666 Oral Deposition of WEATHERS, W.; Vol. 4; Dated 08/24/84 A0667 Oral Deposition of WEATHERS, W.; Vol. 1; Dated 10/23/84 A0668 Oral Deposition of WEATHERS, W.; Vol. 5; Dated 10/24/84 A0669 Oral Deposition of WEATHERS, W.; Vol. 6; Dated 10/25/84 A0670 Oral Deposition of WEBB, J.; Vol. 1; Dated 08/23/83 A0671 Oral Deposition of WEBB, J.; Vol. 2; Dated 08/24/83 A0672 Oral Deposition of WEBB, J.; Vol. 3; Dated 03/08/84 A0673 Oral Deposition of WEBB, J.; Vol. 4; Dated 03/09/84 A0674 Oral Deposition of WEBB, J.; Vol.1; Dated 09/26/84 A0675 Oral Deposition of WEBB, J.; Vol. 1; Dated 10/09/84 (Relating to P.O. 4013)

A0676 Oral Deposition of WEBB, J.; Vol. 1; Dated 10/09/84 (Relating to P.O. 4022)

A0677 Oral Deposition of WEBB, J.; Vol. 1; Dated 02/19/85 A0678 Oral Deposition of WEBB, J.; Vol. 2; Dated 02/20/85 A0679 Oral Deposition of WEBB, J.; Vol. 3; Dated 02/26/85 A - 44 1/21/86

.T 4 -

t, ~

__ _ _ 't' .. .

,. ,9 . - .

'^ ' _

l l

\

Appendix A Document Number Document Title i A0680  !

Oral Deposition of WEBB, J.; Vol. 4; Dated 02/27/85 A0681 Oral Deposition of WEBB, J.; Vol. 5; Dated 03/21/85 l

A0682 Oral Deposition of WEBB, J.; Vol. 6; Dated 04/03/85 A0683 Oral Deposition of WEBB, J.; Vol. 7; Dated 04/04/85 A0684 Oral Deposition of WEINTRAUB, M.; Vol. 1; Dated 01/05/84 A0685 Oral Deposition of WEINTRAUB, M.; Vol. 2; Dated 01/06/84 A0686 Oral Deposition of WEINTRAUB, M.; Vol. 3; Dated 02/02/84 A0687 Oral Deposition of WILKERSON, B.; Vol.1; Dated 02/05/85 A0688 I Oral Deposition of WILKERSON, B.; Vol. 2; Dated 02/26/85 A0689 Oral Deposition of WILLIAMS, E.R.; Vcl.1; Dated 04/16/84 A0690 Oral Deposition of WILLIAMS, T.D.; Vol.1; Dated 06/05/84 A0691 Oral Deposition of WILSON, L.; Vol.1; Dat2d 02/05/85 A0692 Oral Deposition of WILSON, L.; Vol. 2; Dated 02/06/85 A0693 Oral Deposition of WILSON, L.; Vol. 3; Dated 02/07/85 A0694 Oral Deposition of WILSON, L.; Vol. 4; Dated 02/08/85 A0695 Oral Deposition of WILSON, L.; Vol. 5; Dated 03/05/85 A - 45 1/21/86 i

Appendix A Document Number Document Title kbbhh bralbepokkkio of WfLbbh L$; Vo5 b; bat d 03/06/85 A0697 Oral Deposition of WILSON, L.; Vol. 7; Dated l 03/07/85  !

A0698 Oral Deposition of WORMINGTON, W.L.; Vol.1; Dated 04/30/85 .

A0699

}

Oral Deposition of WORMINGTON, W.L.; Vol. 2; Dated i 05/01/85 i

A0700 Oral Deposition of WORMINGTON, W.L.; Vol. 3; Dated \

05/02/85 l A0701 Oral Deposition of WORMINGTON, W.L.; Vol. 4; Dated l 05/06/85 .

A0702 CYGNA Energy Service Report on QA Program and Proc.; Vol.1; Dated 04/30/84 A0703 CYGNA Energy Service Report on QA Program and Proc.; Vol. 2A; Dated 04/30/84 A0704 CYGNA Energy Service Report on QA Program and Proc.; Vol. 2B; Dated 04/30/84 A0705 CYGNA Energy Service Report on QA Program and Proc.; Vol. 2C; Dated 04/30/84 A0706 CYGNA Energy Service Report on QA Program Implementation; Dated 12/17/84 l A0707 J. C. Lavallee Report on NSSS and A/E Interface; Dated 10/01/84 A0708 S. Levy Incorporated Report on B&R Engineering on the STP, Section 1.1.0.; Dated 10/01/84 A0709 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.0, 2.1.; Dated 10/01/84 A0710 S. Levy Incorporated Report on B&R Engineering on the STP, Section 1.2.2.; Dated 10/01/84 A - 46 i

1/21/86

Appendix A Document Number Document Title A0711 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.3.; Dated 10/01/84 A0712 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.4.; Dated 10/01/84 A0713 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.5.; Dated 10/01/84 A0714 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.6.; Dated 10/01/84 A0715 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.7.; Dated 10/01/84 A0716 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.8.; Dated 10/01/84 A0717 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.9.; Dated 10/01/84 A0718 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.10.; Dated 10/01/84 A0719 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.11.; Dated 10/01/84 A0720 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.12.; Dated 10/01/84 A0721 S. Levy Incorporated Report on B&R Engineering on the STP, Section 1.2.13.; Dated 10/01/84 A0722 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.14.; Dated 10/01/84 A0723 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.15.; Dated 10/01/84 A0724 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.16.; Dated 10/01/84 A0725 S. Levy Incorporated Report on B&R Engineering on the STP, Section 1.2.17.; Dated 10/01/84 A - 47 1/21/86 9

.- , . - . , - - - . , - .c -

,, ---- - , - e, p,.----,

Appendix A l

Document Number Document Title A0726 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.18.; Dated 10/01/84 A0727 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.19.; Dated 10/01/84 A0728 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.20.; Dated 10/01/84 A0729 S. Levy Incorporated Report on B&R Engineering on t

the STP,Section I.2.21.; Dated 10/01/84 A0730 S. Levy Incorporated Report on B&R Engineering on i t

the STP,Section I.2.22.; Dated 10/01/84 A0731 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.23.; Dated 10/01/84 A0732 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.24.; Dated 10/01/84 )

i A0733 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.25.; Dated 10/01/84 A0734 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.26; Dated 10/01/84 A0735 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.27.; Dated 10/01/84 A0736 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.28.; Dated 10/01/84 A0737 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.29.; Dated 10/01/84 A0738 S. Levy Incorporated Report on B&R Engineering on the STP,Section I.2.30.; Dated 10/01/84 i A0739 S. Levy Incorporated Report on B&R Engineering on  !

~

the STP, Section 11.3.0, II.3.1.; Dated 10/01/84  !

A0740 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.3.2.; Dated 10/01/84 A - 48 1/21/86 i

I l

l Appendix A Document Number Document Title A0741 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.3.3.; Dated 10/01/84 A0742 i S. Levy Incorpora.ted Report on B&R Engineering on the STP,Section II.3.4.; Dated 10/01/84 1

A0743 S. Levy Incorporated Report on B&R Engineering on i the STP,Section II.3.5.; Dated 10/01/84 A0744 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.3.6.; Dated 10/01/84 A0745 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.3.7.; Dated 10/01/84 A0746 S. Levy Incorporated Report on B&R Engineering on the STP, Section 11.4.0, II.4.1.; Dated 10/01/84 A0747 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.4.2.; Dated 10/01/84 A0748 S. Levy Incorporated Report on B&R Engineering on the STP, Section 11.4.3.; Dated 10/01/84 A0749 S. Levy Incorporated Report on B&R Engineering on the STP, Section 11.4.4.; Dated 10/01/84 A0750 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.4.5.; Dated 10/01/84 A0751 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.4.6.; Dated 10/01/84 A0752 S. Levy Incorporated Report on B&R Engineering on the STP, Section 11.4.7.; Dated 10/01/84 A0753 S. Levy Incorporated Report on B&R Engineering on the STP,Section II.5.0.; Dated 10/01/84 A0754 S. Levy Incorporated Report on B&R Engineering on the STP, Section I1.5.1.; Dated 10/01/84 A0755 1 S. Levy Incorporated Report on B&R Engineering on the STP, Section 1I.5.2.; Dated 10/01/84 A - 49 1/21/86

! l l

1 Appendix A '

Document Number Document Title

................................................... l A0756 S. Levy Incorporated Report on B&R Engineering on the STP, Section 11.5.3.; Dated 10/01/84 l A0757 S. Levy Incorporated Report on B&R Engineering on the STP, Section 11.6,0.; Dated 10/01/84

{

A0758 J. R. Wells Report on Concrete Work on the STP; 4

Dated 09/26/84 A0759 Bechtel Response to B&R Written Depositions Relating to Work Package EA-002; Dated 07/27/84 A0760 Bechtel Response to B&R Written Depositions Relating to Work Package EA-003; Dated 07/27/84 A0761 Bechtel Response to B&R Written Depositions Relating to Work Package EA-004; Dated 07/27/84 A0762 Bechtel Response to B&R Written Depositions Relating to Work Package EA-005; Dated 07/27/84 A0763 Bechtel Response to B&R Written Depositions Relating to Work Package EA-006; Dated 07/27/84 A0764 Bechtel Response to B&R Wricten Depositions Relating to Work Package EA-007; Dated 07/27/84 A0765 Bechtel Response to B&R Written Depositions Relating to Work Package EA-008; Dated 07/27/84 A0766 Bechtel Response to B&R Written Depositions Relating to Work Package EA-010; Dated 07/27/84 A0767 Bechtel Response to B&R Written Depositions Relating to Work Package EA-011; Dated 07/27/84 A0768 Bechtel Response to B&R Written Depositions Relating to Work Package EA-012; Dated 07/27/84 A0769 Bechtel Response to B&R Written Depositions

, Relating to Work Package EA-013; Dated 07/27/84 A07f0 Bechtel5 Response to B&R Written Depositions Relating

• to Work Package EA-014; Dated 07/27/84 A - 50 1/21/86

. . _ , __ _ __ _y , _ _,

Appendix A Document Number Document Title A0771 Bechtel Response to B&R Written Depositions Relating to Work Package EC-100/101; Dated 07/27/84 A0772 Bechtel Response to B&R Written Depositions Relating to Work Package EC-102; Dated 07/27/84 A0773 Bechtel Response to B&R Written Depositions Relating to Work Package EC-103; Dated 07/27/84 A0774 Bechtel Response to B&R Written Depositions Relating to Work Package EC-104; Dated 07/27/84 A0775 Bechtel Response to B&R Written Depositions Relating to Work Package EC-105; Dated 07/27/84 A0776 Bechtel Response to B&R Written Depositions Relating to Work Package EC-110-113; Dated 07/27/84 A0777 Bechtel Response to B&R Written Depositions Relating to Work Package EC-120-121; Dated 07/27/84 j

A0778 Bechtel Response to B&R Written Depositions {

Relating to Work Package EC-122; Dated 07/27/84 A0779 Bechtel Response to B&R Written Depositions Relating to Work Package EC-130-132; Dated 07/27/84 l

A0780 Bechtel Response to B&R Written Depositions Relating to Work Package EC-135; Dated 07/27/84 i

A0781 Bechtel Response to B&R Written Depositions Relating to Work Package EC-138; Dated 07/27/84 A0782 Bechtel Response to B&R Written Depositions 1 Relating to Work Facnage EC-140; Dated 07/27/84 A0783 Bechtel Response to B&R Written Depositions Relating to Work Package EC-142/EM-510; Dated i 07/27/84 A0784 Bechtel Response to B&R Written Depositions Relating to Work Package EC-145; Dated 07/27/84  ;

A0785 Bechtel Response to B&R Written Depositions Relating to Work Package EC-150; Dated 07/27/84 A - 51 1/21/86

l l

l

.\

Appendix A 1

Document Number Document Title l 1

A0786 Bechtel Response to B&R Written Depositions Relating to Work Package EC-151; Dated 07/27/84 A0787 Bechtel Response to B&R Written Depositions i Relating to Work Package EC-155; Dated 07/27/84 '

A0788 Bechtel Response to B&R Written Depositions Relating to Work Package EC-157; Dated 07/27/84 {

A0789 Bechtel Response to B&R Written Depositions Relating to Work Package EC-160; Dated 07/27/84 1

A0790 Bechtel Response to B&R Written Depositions t Relating to Work Package EC-161; Dated 07/27/84 A0791 Bechtel Response to B&R Written Depositions i Relating to Work Package EC-162; Dated 07/27/84 A0792 Bechtel Response to B&R Written Depositions i Relating to Work Package EC-163; Dated 07/27/84 A0793 Bechtel Response to B&R Written Depositions Relating to Work Package EC-165; Dated 07/27/84 A0794 Bechtel Response to B&R Written Depositions Relating to Work Package EC-170; Dated 07/27/84 A0795 Bechtel Response to B&R Written Depositions Relating to Work Package EC-171; Dated 07/27/84 A0796 Bechtel Response to B&R Written Depositions Relating to Work Package EC-172; Dated 07/27/84 A0797 Bechtel Response to B&R Written Depositions Relating to Work Package EC-173; Dated 07/27/84 A0798 Bechtel Respon::e to B&R Written Depositions Relating to Work Package EC-174; Dated 07/27/84 A0799 I Bechtel Response to B&R Written Depositions i

Relating to Work Package EC-175; Dated 07/27/84 i

A0800 Bechtel Response to B&R Written Depositions Relating to Work Package EC-176; Dated 07/27/84 A - 52 1/21/86

l l

Appendix A Document Number Document Title A0801 Bechtel Response to B&R Written Depositions Relating to Work Package EC-177; Dated 07/27/84 A0802 Bechtel Respoese to B&R Written Depositions Relating to Wor k Package EC-181; Dated 07/27/84 i A0803 Bechtel Response to MR Written Depositions I

j Relating to Work Package EC-186; Dated 07/27/84 j A0804 Bechtel Response to B&R Written Depositions i Relating to Work Package EC-195; Dated 07/27/84 A0805 Bechtel Response to B&R Written Depositions .

Relating to Work Package EE-200; Dated 07/27/84 l A0806 Bechtel Response to B&R Written Depositions i

Relating to Work Package EE-201; Dated 07/27/84 A0807 Bechtel Response to B&R Written Depositions Relating to Work Package EE-202; Dated 07/27/84 A0808 Bechtel Response to B&R Written Depositions .

Relating to Work Package EE-203; Dated 07/27/84 ,

A0809 Bechtel Response to B&R Written Depositions Relating to Work Package EE-204; Dated 07/27/84 '

A0810 Bechtel Response to B&R Written Depositions Relating to Work Package EE-205; Dated 07/27/84 A0811 Bechtel Response to B&R Written Depositions Relating to Work Package EE-206; Dated 07/27/84 A0812 l

Bechtel Response to B&R Written Depositions Relating to Work Package EE-207; Dated 07/27/84 [

A0813 Bechtel Response to B&R Written Depositions Relating to Work Package EE-208; Dated 07/27/84  !

L A0814 i Bechtel Response to B&R Written Depositions l

Relating to Work Package EE-209; Dated 07/27/84 ,

A0815 Bechtel Response to B&R Written Depositions Relating to Work Package EE-210; Dated 07/27/84  !

A - 53 1/21/86 '

l l

Appendix A l

Document Number Document Title A0816 Bechtel Response to B&R Written Depositions Relating to Work Package EE-211; Dated 07/27/84 A0817 Bechtel Response to B&R Written Depositions Relating to Work Package EE-212; Dated 07/27/84 A0818 Bechtel Response t) B&R Written Depositions Relating to Work Package EE-213; Dated 07/27/84 A0819 Bechtel Response to B&R Written Depositions Relating to Work Package EE-214; Dated 07/27/84 A0820 Bechtel Response to B&R Written Depositions Relating to Work Package EE-215; Dated 07/27/84 A0821 Bechtel Response to B&R Written Depositions Relating to Work Package EE-216; Dated 07/27/84 l

A0822 Bechtel Response to B&R Written Depositions i Relating to Work Package EE-217; Dated 07/27/84 A0823 Bechtel Response to B&R Written Depositions Relating to Work Package EE-218/EJ-321; Dated 07/27/84 A0824 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E21 through E26; Dated 07/27/84 A0825 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E32 through E36; Dated 07/27/84 1 A0826 Bechtel Response to B&R Written Depositions i

Relr. ting to Work Package EE-219-E41A and E43-C; Dated 07/27/84 A0827 Bechtel Response to B&R Written Depositions i Relating to Work Package EE-219-E43; Dated 07/27/84 A0828 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E44 and E45; Dated 07/27/84 1

A - 54 1/21/86 l 4 i

Appendix A Document Number .

Document Title A0829 ...................................................

Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E46; Dated 07/27/84 A0830 Bechtel Response to B&R Written Depositions  !

Relating to Work Package EE-219-E51; Dated 07/27/84 A0831 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E52; Dated 07/27/84 A0832 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E53 and E54; Dated 07/27/84 j i

A0833 Bechtel Response to B&R Written Depositions 1 Relating to Work Package EE-219-E61 through E66; }

Dated 07/27/84 i A0834 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E71; Dated 07/27/84 A0835 l Bechtel Response to B&R Written Depositions I i

Relating to Work Package EE-219-E72; Dated 07/27/84  !

A0836 Bechtel Response to B&R Written Depositions Relating to Work Package EE-219-E73; Dated 07/27/84 A0837 ,

Bechtel Response to B&R Written Depositions i Relating to Work Package EE-219-E74; Dated 07/27/84 A0838 Bechtel Response to B&R Written Depositions Relating to Work Package EE-220; Dated 07/27/84 A0839 Bechtel Response to B&R Written Depositions Relating to Work Package EE-222; Dated 07/27/84 i A0840 Bechtel Response to B&R Written Depositions Relating to Work Package EE-223; Dated 07/27/84 A0841 Bechtel Response to B&R Written Depositions Relating to Work Package EE-224; Dated 07/27/84 I A0842 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-300; Dated 07/27/84 A - 55 1/21/86

Appendix A Document Number Document Title A0843 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-301; Dated 07/27/84 A0844 Bechtel Response to B&R Written Depositions i Relating to Work Package EJ-303; Dated 07/27/84 A0845 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-306; Dated 07/27/84  :

A0846 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-310; Dated 07/27/86 A0847 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-313; Dated 07/27/84 A0848 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-314; Dated 07/27/84 A0849 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-315; Dated 07/27/84 A0850 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-316; Dated 07/27/84 A0851 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-317; Dated 07/27/84 A0852 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-318; Dated 07/27/84 A0853 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-351; Dated 07/27/P4 A0854 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-352; Dated 07/27/84 A0855 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-353; Dated 07/27/84 A0856 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-354; Dated 07/27/84 A0857 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-355; Dated 07/27/84 A - 56

, 1/21/86 l

Appendix A Document l Number Document Title A0858 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-356; Dated 07/27/84 A0859 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-358; Dated 07/27/84 A0860 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-360; Dated 07/27/84 A0861 Bechtel Response to B&R Written Depositions Relating to Wark Package EJ-361; Dated 07/27/84 A0862 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-362; Dated 07/27/84 A0863 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-364; Dated 07/27/84 A0864 Bechtel Response to B&R Written Depositions 1 Relating to Work Package EJ-365; Dated 07/27/84 A0865 Bechtel Response to B&R Written Depositions i Relating to Work Package EJ-366; Dated 07/27/84  !

A0866 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-367; Dated 07/27/84 1

A0867 Bechtel Response to B&R Written Depositions  !

Relating to Work Package EJ-308; Dated 07/27/84 '

l A0868 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-369; Dated 07/27/84 '

A0869  !

Bechtel Response to B&R Written Depositions '

Relating to Work Package EJ-370; Dated 07/27/84 i A0870 Bechtel Response to B&R Written Depositions Relating to Work Package EJ-371; Dated 07/27/84 A0871 I Bechtel Response to B&R Written Depositions  !

Relating to Work Package EJ-372; Dated 07/27/84 l i

A0872 Bechtel Response to B&R Written Depositions t Relating to Work Package EJ-373; Dated 07/27/84 '

l l

A - 57 1/21/86 l

l i

i Appendix A Document Number Document Title A0873 ...................................................

Bechtel Response to B&R Written Depositions

)

Relating to Work Package EM-400; Dated 07/27/84 A0874 Bechtel Response to B&R Written Depositions Relating to Work Package EM-401; Dated 07/27/84 A0875 Bechtel Response to B&R Written Depositions Relating to Work Package EM-402; Dated 07/27/84 A0876 Bechtel Response to B&R Written Depositions Relating to Work Package EM-403; Dated 07/27/84 A0877 Bechtel Response to B&R Written Depositions Relating to Work Package EM-404; Dated 07/27/84 A0878 Bechtel Response to B&R Written Depositions Relating to Work Package EM-405; Dated 07/27/84 A0879 Bechtel Response to B&R Written Depositions Relating to Work Package EM-406A; Dated 07/27/84 A0880 Bechtel Response to B&R Written Depositions i

Relating to Work Package EM-406B; Dated 07/27/84 A0881 Bechtel Response to d&R Written Depositions Relating to Work Package EM-407; Dated 07/27/84 A0882 Bechtel Response to B&R Written Depositions 1 Relating to Work Package EM-408; Dated 07/27/84 A0883 Bechtel Response to B&R Written Depositions Relating to Work Package EM-409; Dated 07/27/84 A0884 Bechtel Response to B&R Wr.itten Depositions Relating to Work Package EM-410; Dated 07/27/84 j i

A0885 Bechtel Response to B&R Written Depositions Relating to Work Package EM-411; Dated 07/27/84 A0886 Bechtel Response to B&R Written Depositions Relating to Work Package EM-412; Dated 07/27/84 A0887 Bechtel Response to B&R Written Depositions Relating to Work Package EM-413; Dated 07/27/84 A - 58 1/21/86

Appendix A Document Number Document Title A0888 Bechtel Response to B&R Written Depositions Relating to Work Package EM-450; Dated 07/27/84 A0889 Bechtel Response to B&R Written Depositions Relating to Work Package EM-451/EM-452; Dated 07/27/84 A0890 Bechtel Response to B&R Written Depositions Relating to Work Package EM-453; Dated 07/27/84 A0891 Bechtel Response to B&R Written Depositions Relating to Work Package EM-454; Dated 07/27/84 A0892 Bechtel Response to B&R Written Depositions Relating to Work Package EM-455; Dated 07/27/84 A0893 Bechtel Response to B&R Written Depositions Relating to Work Package EM-456; Dated 07/27/84 A0894 Bechtel Response to B&R Written Depositions Relating to Work Package EM-457; Dated 07/27/84 A0895 Bechtel Response to B&R Written Depositions Relating to Work Package EM-459; Dated 07/27/84 A0896 Bechtel Response to B&R Written Depositions Relating to Work Package EM-500; Dated 07/27/84 A0897 Bechtel Response to B&R Written Depositions Relating to Work Package EM-501; Dated 07/27/84 A0898 Bechtel Response to B&R Written Depositions Relating to Work Package EM-502; Dated 07/27/84 A0899 Bechtel Response to B&R Written Depositions Relating to Work Package EM-503; Dated 07/27/84 A0900 Bechtel Response to B&R Written Depositions Relating to Work Package EM-504; Dated 07/27/84 A0901 Bechtel Response to B&R Written Depositions Relating to Work Package EM-505; Dated 07/27/84 A0902 Bechtel Response to B&R Written Depositions Relating to Work Package EM-507; Dated 07/27/84 A - 59 1/21/86

1 l

Appendix A Document Number Document Title

................................................... i A0903 Bechtel Response to B&R Written Depositions Relating to Work Package EM-508; Dated 07/27/84 A0904 Bechtel Response to B&R Written Depositions Relating to Work Package EM-509; Dated 07/27/84 A0905 Bechtel Response to B&R Written Depositions Relating to Work Package EM-510; Dated 07/27/84 A0906 Bechtel Response to B&R Written Depositions Relating to Work Package EM-511; Dated 07/27/84 A0907 Bechtel Response to B&R Written Depositions Relating to Work Package EM-512; Dated 07/27/84 A0908 Bechtel Response to B&R Written Depositions Relating to Work Package EM-513; Dated 07/27/84 A0909 Bechtel Response to B&R Written Depositions Relating to Work Package EM-514; Dated 07/27/84 A0910 Bechtel Response to B&R Written Depositions Relating to Work Package EM-515; Dated 07/27/84 A0911 Bechtel Response to B&R Written Depositions Relating to Work Package EM-517; Dated 07/27/84 A0912 Bechtel Response to B&R Written Depositions Relating to Work Package EM-518; Dated 07/27/84 A0913 Bechtel Response to B&R Written Depositions Relating to Work Package EM-519; Dated 07/27/84 A0914 Bechtel Response to B&R Written Depositions Relating to Work Package EM-520; Dated 07/27/84 A0915 Bechtel Response to B&R Written Depositions Relating to Work Package EM-522; Dated 07/27/84 A0916 Bechtel Response to B&R Written Depositions Relating to Work Package EM-523; Dated 07/27/84 A0917 Bechtel Response to B&R Written Depositions 1

Relating to Work Package EM-524; Dated 07/27/84 '

l A - 60 f

1/21/86

- - .~,

Appendix A Document Number Document Title A0918 Bechtel Response to B&R Written Depositions Relating to Work Package EM-525; Dated 07/27/84 A0919 Bechtel Response to B&R Written Depositions Relating to Work' Package EM-526; Dated 07/27/84 A0920 Bechtel Response to B&R Written Depositions Relating to Work Package EM-527; Dated 07/27/84 A0921 Bechtel Response to B&R Written Depositions Relating to Work Package EM-550; Dated 07/27/84 A0922 Bechtel Response to B&R Written Depositions Relating to Work Package EM-551; Dated 07/27/84 A0923 Bechtel Response to B&R Written Depositions Relating to Work Package EM-552; Dated 07/27/84 A0924 Bechtel Response to B&R Written Depositions Relating to Work Package EM-553; Dated 07/27/84 A0925 Bechtel Resporse to B&R Written Depositions Relating to F . k Package EM-554; Dated 07/27/84 A0926 Bechtel Response to B&R Written Depositions Relating to Work Package EM-555; Dated 07/27/84 A0927 Bechtel Response to B&R Written Depositions Relating to Work Package EM-556; Dated 07/27/84 l A0928 Bechtel Response to B&R Written Depositions l

Relating to Work Package EM-557; Dated 07/27/84 A0929 Bechtel Response to B&R Written Depositions Relating to Work Package EM-558; Dated 07/27/84 A0930 Bechtel Response to B&R Written Depositions Relating to Work Package EM-559; Dated 07/27/84 A0931 Bechtel Response to B&R Written Depositions Relating to Work Package EM-560; Dated 07/27/84 A0932 Bechtel Response to B&R Written Depositions Relating to Work Package EM-561; Dated 07/27/84

, A - 61 1/21/86

Appendix A Document Number Document Title A0933 Bechtel Response to B&R Written Depositions Relating to Work Package EM-562; Dated 07/27/84 A0934 Bechtel Response to B&R Written Depositions Relating to Work Package EM-563; Dated 07/27/84 A0935 Bechtel Response to B&R Written Depositions Relating to Work Package EM-564; Dated 07/27/84  !

A0936 Bechtel Response to B&R Written Depositions j Relating to Work Package EM-565; Dated 07/27/84 A0937 Bechtel Response to B&R Written Depositions Relating to Work Package EM-566; Dated 07/27/84 A0938 Bechtel Response to B&R Written Depositions Relating to Work Package EM-567; Dated 07/27/84 A0939 Bechtel Response to B&R Written Depositions Relating to Work Package EM-568; Dated 07/27/84 A0940 Bechtel Response to B&R Written Depositions Relating to Work Package EM-569; Dated 07/27/84 A0941 Bechtel Response to B&R Written Depositions Relating to Work Package EM-570; Dated 07/27/84 A0942 Bechtel Response to B&R Written Depositions Relating to Work Package EM-371; Dated 07/27/84 A0943 Bechtel Response to B&R Written Depositions I Relating to Work Package EM-572; Dated 07/27/84 A0944 Bechtel Response to B&R Written Depositions Relating to Work Package EN-600; Dated 07/27/84 '

A0945 Bechtel Response to B&R Written Depositions l Relating to Work Package EN-601; Dated 07/27/84

{

A0946 Bechtel Response to B&R Written Depositions i Relating to Work Package EN-602; Dated 07/27/84 A0947 Bechtel Response to B&R Written Depositions .

Relating to Work Package EN-603; Dated 07/27/84 A - 62 1/21/86 l

Appendix A Document Number Document Title A0948 Bechtel Response to B&R Written Depositions Relating to Work Package EN-604; Dated 07/27/84 A0949 Bechtel Response to B&R Written Depositions Relating to Work Package EN-605; Dated 07/27/84 A0950 Bechtel Response to B&R Written Depositions i Relating to Work Package EN-606; Dated 07/27/84 A0951 Bechtel Response to B&R Written Depositions  !

Relating to Work Package EN-612; Dated 07/27/84 l

A0952 Bechtel Response to B&R Written Depositions l Relating to Work Package EN-613; Dated 07/27/84 i A0953 Bechtel Response to B&R Written Depositions Relating to Work Package EN-614; Dated 07/27/84 A0954 Bechtel Response to B&R Written Depositions Relating to Work Package EN-615; Dated 07/27/84 A0955 Bechtel Response to B&R Written Depositions Relating to Work Package EN-616; Dated 07/27/84 A0956 Bechtel Response to B&R Written Depositions Relating to Work Package EN-618; Dated 07/27/84 A0957 Bechtel Response to B&R Written Depositions Relating to Work Package EN-619; Dated 07/27/84 i A0958 Bechtel Response to B&R Written Depositions Relating to Work Package EN-530; Dated 07/27/84 i t

A0959 Bechtel Response to B&R Written Depositions Relating to Work Package EP-700; Dated 07/27/84 A0960 Bechtel Response to B&R Written Depositions Relating to Work Package EP-701; Dated 07/27/84 A0961 Bechtel Response to B&R Written Depositions Relating to Work Package EP-702/703; Dated 07/27/84 A0962 Bechtel Response to B&R Written Depositions Relating to Work Package EP-704; Dated 07/27/84 i

A - 63 4 1/21/86

Appendix A Document Number Document Title A0963 Bechtel Response to B&R Written Depositions Relating to Work Package EP-705; Dated 07/27/84 A0964 Bechtel Response to B&R Written Depositions Relating to Work Package EP-706; Dated 07/27/84 A0965 Bechtel Response to B&R Written Depositions Relating to Work Package EP-707; Dated 07/27/84-A0966 Bechtel Response to B&R Written Depositions Relating to Work Package EP-708; Dated 07/27/84 i

A0967 Bechtel Response to B&R Written Depositions l i

Relating to Work Package EP-709; Dated 07/27/84 A0968 Bechtel Response to B&R Written Depositions Relating to Work Package EP-714; Dated 07/27/84 A0969 Answers to B&R's 1st set to HL&P; Dated 03/31/82 A0970 Answers to B&R's 1st set to CP&L; Dated 04/12/82 A0971 Answers to B&R's 1st set to City of San Antonio; Dated 04/15/82 A0972 Answers to B&R's 1st set to City of Austin; Dated 04/16/82  !

A0973 Answers to Halliburton's 1st set to HL&P; Dated 05/17/82 i A0974 Answers to Halliburton's 1st set to City of Austin; Dated 05/17/82 A0975 Answers to Ha111 burton's 1st set to City of San Antonio; Dated 05/17/82 A0976 Answers to Halliburton's 1st set to CP&L; Dated 05/17/82 A0977 Answers to CP&L's 1st set to Halliburton; Dated 08/02/82 A0978 Answers to HL&P's 1st set to B&R; Dated 09/03/82 A - 64 1/21/86

l l

l l

Appendix A l

Document Number Document Title A0979 Answers to City of Austin's 1st set to Halliburton; Dated 09/22/82 A0980 Answers to B&R's 2nd set to HLAP; Dated 12/10/82 A0981 Answers to City of San Antonio's 1st set to I Halliburton; Dated 12/10/82 l i

A0982 Answers to B&R's 2nd set to City of Austin; Dated 1 01/24/83 1 A0983 Answers to HL&P's 2nd set to B&R; Dated 02/16/83 1

i A0984 Response to HL&P's request for admissions pursuant to Rule 169; Dsted 02/16/83 A0985 Answers to B&R's 3rd set to HL&P; Dated 03/16/83 A0986 Answers to B&R's 4th set to HL&P; Dated 04/27/83 A0987 Answers to HL&P's amended 2nd set to B&R; Dated 05/23/83 i A0988 Answers to HL&P's 3rd set to B&R; Dated 07/25/83  !

A0989 Answers to HL&P's 4th set to Halliburton & B&R; Dated 10/03/83 i A0990 Response to HL&P's 5th request for admissions pursuant to Rule 169; Dated 10/05/83 A0991 Response to HL&P's 6th request for admissions pursuant to Rule 169; Dated 10/05/83 i A0992 Response to City of Austin's 1st request for admissions; Dated 10/26/83 i A0993 Answers to HL&P's 6th set to B&R; Dated 10/31/83 A0994 Answers to B&R's 6th set to HL&P; Dated 10/31/83 l A0995 ' Response to City of Austin's 2nd request for admissions; Dated 11/04/83 l

A - 65 1/21/86

. l 1

k l

Appendix A Document Number

'ocument Title A0996 Response to San Antonio's 1st request for admissions pursuant to Rule 169; Dated 11/14/83 A0997 Response to 2nd request for admissions to B&R; Dated 11/21/83 A0998 Answers to B&R's 7th set to HL&P; Dated 12/01/83 A0999 Response to 3rd request for admissions to B&R; Dated 12/21/83 A1000 l J Answers to HL&P's lith set to B&R; Dated 01/16/84 A1001 Answers to Halliburton's 4th set to HL&P; Dated 01/18/84 ,

A1002 Answers to Halliburton's 4th set to City of Austin; Dated 01/18/84 A1003 Answers to Halliburton's 4th set to CP&L; Dated 01/18/84 A1004 Answers to Halliburton's 4th set to City of San Antonio; Dated 01/18/84 A1005 Answers to B&R's 9th set to HL&P (Initial answers);

Dated 02/01/84 A1006 Supplemental 2nd Answers to B&R's 9th set to HL&P; Dated 02/01/84 A1007 Answers to B&R's 4th set to CP&L; Dated 02/01/84 A1008 Answers to B&R's 5th set to City of Austin; 2 Sets:

Dated 02/01/84; 02/14/84 A1009  !

1 Answers to HL&P's 13th set to B&R; Dated 02/06/84 A1010 Answers to Halliburton's 5th set to City of. Austin; ,

Dated 02/06/84 A10ll Answers to Halliburton's 5th set to City of San Antonio; Dated 02/06/84 A - 66 1/21/86 l

1 Appendix A Document

' lumber Document Title A1012 Answers to Halliburton's 5th set to HL&P; Dated 1 i

02/06/84 l A1013 Answers to Halltburton's 5th set to CP&L; Dated 02/06/84 A1014 Answers to City of Austin's 4th set to B&R; Dated 02/17/84 l l

A1015 Answers to City of Austin's 5th set to Halliburton; Dated 02/17/84 A1016 Response to HL&P's 8th request for admissions; Dated 02/22/84 -

A1017 Response to HL&P's 9th request for admissions; l Dated 02/22/84 A1018 Response to HL&P's 10th request for admissions; Dated 02/2?/84 A1019 Answers to B&R's 10th set to HL&P; Dated 02/27/84 A1020 Answers to City of Austin's 6th set to B&R; Dated 03/02/84  !

A1021 Answers to City of San Antonio's 2nd set to Halliburton; Dated 03/05/84 A1022 I Answers to HL&P's 14th set to B&R; Dated 04/16/84 A1023 Answers to B&R's 12th set to HL&P; Dated 04/16/84 A1024 Answers to B&R's 13th set to HL&P; Dated 05/04/84 A1025 Response to 4th request for admissions to B&R; Dated 05/11/84 A1026 Answers to City of Austin's 7th set to B&R; Dated C5/15/84 A1027 Answers to City of Austin's 8th set to B&R; Dated 05/21/84 A - 67 1/21/85 l

i Appendix A Document Number Document Title A1028 Answers to B&R's 7th set to City of Austin; Dated ,

05/24/84 i A1029 Answers to B&R's 5th set to City of San Antonio; I Dated 05/24/84  !

A1030 i l Answers to B&R's 5th set to CP&L; Dated 06/08/84 1 (Answers filed 07/23/84)

A1031 Answers to B&R's 5th set to CP&L; Dated 06/08/84 (Answers filed 08/01/84 and 11/07/84)

A1032 Answers to B&R's 14th set to HL&P; Dated 06/08/84 A1033 Answers to B&R's 8th set to City of Austin; Dated i

06/08/84 i A1034 Answers to B&R's 6th set to City of San Antonio; t

i Dated 06/08/84 j A1035 Answers to B&R's 14th set to HL&P; Dated 06/14/84 A1036 Answers to HL&P's 19th set to B&R and Halliburton; Dated 06/21/84 A1037 Answers to B&R's 15th set to HL&P; Dated 07/02/84 A1038 Answers to B&R's 16th set to HL&P; Dated 07/09/84 A1039 Answers to B&R's 18th set to HL&P; Dated 07/20/84 A1040 Answers to HL&P's 21st set to B&R and Halliburton; Dated 07/23/84 A1041  !

Answers to HL&P's 22nd set to B&R and Halliburton; Dated 07/23/84 j A1042 Answers to HL&P's 23rd set to B&R and Halliburton; Dated 07/23/84 I i

A1043  !

Answers to HL&P's 24th set to B&R and Halliburton; Dated 07/23/84 A1044 Answers to HL&P's 25th set to B&R and Halliburton Dated 07/23/84 A - 68 1/21/86 {

Appendix A Document tiumber Document Title A1045 Answers to HL&P's 26th set to B&R and Halliburton; Dated 07/23/84 A1046 Answers to HL&P's 27th set to B&R and Halliburton; Dated 07/23/84 A1047 Answers to HL&P's 28th set to B&R and Halliburton; Dated 07/23/84 A1048 Answers to HL&P's 29th set to B&R and Halliburton; Dated 07/23/84 A1049 Answers to HL&P's 30th set to B&R and Halliburton; Dated 07/23/84 A1050 Answers to HL&P's 31st set to B&R and Halliburton; Dated 07/23/84 A1051 Answers to HL&P's 32nd set to B&R and Halliburton; Dated 07/23/84 -

A1052 Answers to HL&P's 33rd set to B&R and Halliburton; Dateo 07/23/84 A1053 Answers to HL&P's 34th set to B&R and Halliburton; Dated 07/23/84 A1054 Answers to HL&P's 35th set to B&R and Halliburton; Dated 07/23/84 A1055 Response to City of San Antonio's 4th request for admissions and 5th set to B&R; Dated 07/23/84 A1056 Answers to HL&P's 36th set to B&R; Dated 07/30/84 A1057 Answers to B&R's 19th set to HL&P; Dated 08/08/84 A1058 Answers to B&R's 7th set to CP&L; Dated 08/08/84 A1059 Ar.swers to B&R's 9th set to City of Austin; Dated 08/08/84 A1060 Answers to B&R's 7th set to City of San Antonio; Dated 08/08/84 3 1

A - 69 1/21/86 i

l

Appendix A Document I

..k"I'[ .

................9933?'"b.I.Ibl.?....................

A1061 Answers to Halliburton's 6th set to CP&L; Dated 08/20/84 A1062 Answers to Halliburton's 6th sat to City of Austin; Dated 08/20/84 A1063 Answers to Halliburton's 6th set to City of San Antonio; Dated 08/20/84 A1064 Answers to B&R's 10th set to City of Austin; Dated 08/21/84 A1065 Answers to B&R's 8th set to CP&L; Dated 08/21/84 A1066 Answers to B&R's 8th set to City of San Antonio; Dated 08/21/84 A1067 Answers to HL&P's 38th set to B&R and Halliburton; 4

Dated 09/10/84 A1068 Answers to D&R's 9th set to City of San Antonio; Dated 09/11/84 A1069 Answers to B&R's 20th set to HL&P;tDated 09/11/84 A1070 Answers to B&R's lith set to City of Austin; Dated 09/11/84 A1071 Answers to B&R's 9th set to CP&L; Dated 09/11/84 A1072 Answers to B&R's 21st set to HL&P; Dated 09/26/84 A1073 Answer s to B&R's 10th set to City of San' Antonio; Dated 09/26/84 A1074 Answers to B&R's 12th set to City of Austin; Dated 09/26/84 A1075 Answers to B&R's 10th set to CP&L; Dated 09/26/84 A1076 Answers to City of San Antonio's 6th set to B&R; Dated 11/14/84 A1077 Answers to B&R's amended 17th set to HL&P; Dated 01/23/85 A . 70 '1/21/86

l l

1 l

Appendix A Occument i Number Document Title

[bhb l knswhrskbhkksh4khskkokkhbakedbhh[h/8h A1079 Answers to B&R's 26th set to HL&P; Dated 03/22/85 A1080 Answers to B&R's 28th set to HL&P; Dated 04/29/85 A1081 Answers to B&R's 29th set to HL&P; Dated 05/13/85 00CUMENTS NOT REVIEWED \

HL&P's 3rd request for admissions pursuant to Rule 169; dated 03/18/83 HL&P's 2nd request for admissions pursuant to Rule 169; dated 03/22/83 l 1st request for admissions to B&R; dated 11/21/83

%R's 4th set to City of San Antonio; dated 02/10/84 HL&P's 18th set to B&R; dated 06/18/84 HL&P's 20th set to B&R; dated 07/02/84 B&R's 17th set to HL&P; dated 07/20/84 City of Austin's 10th set to B&R; dated 08/16/84 Halliburton's 6th set to HL&P; dated 08/20/84 City of Austin's lith set to B&R; dated 09/24/84 I City of Austin's 12th set to B&R; dated 09/24/84 Halliburton's 7th set to City of Austin; dated 10/22/84

~

Halliburton's 7th set to HL&P; dated 10/22/84 Halliburton's 7th set to CP&L; dated 10/22/84  !

I Halliburton's 7th set to City of San Antonio; dated 10/22/84 B&R's 13th set to CP&L; dated 11/26/84 Halliburton's 8th set to City of Austin; dated 02/11/85 Halliburton's 8th set to City of San Antonio; dated 02/11/85 A-71 1

7 o; '

- ly 3 , ,.,- ,e -

7 j . ,

,j

' i DOCUMENTS NOT REVIEWED (Contd.)

Halliburton's 8th set to CP&L; dated 02/21/85

/~.

'T Q8.

I, Halliburton's 8th' sat toi ell &P; d.at.ed 02/1.1/85 B&Rts-14th set tc -CP&L';' dated 02?13/05 s HL&P's 39th set to 8$; date'ol02/19/85 > -

s HL&PIs45thset,toB&R; dated 03/13/85~ .

j B&R's 15th' set to City of San Antonio; dated 03/22/85 B&R's 15th set to CP&L; dated 03/22/85 -

B&R's 17th set to City of Austin; dated 03/22/85 {

- /

CityofSanAntonio's7thsettoS$R; dated 04/26/85 -

BLU s 19th set to City.,0f' Austin; dated 04/29/85 B&R's 17th set to CP&L:idated 04/29/85 ,

BLR's 17th set to City'of San Antonio; dated 04/29/85 SL&P's 41st set to B&R; dated'05/09/85 ~

BLR's 30th set to HL&P; dated 05/15/85 hvt

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APPENDIX B Appendix B lists the persons who participated in SLI's review of the documents listed in Appendix A.

These individuals are divided into four groups: Team Leaders, Overview Specialists, Discipline Specialists, and Reviewers. Each per-son is listed in the highest category for which he or she is qualified by education and experience. Team Leader is the designation for an individual whose education and experience qualify him to perform all or any portion of the Review. A Team Leader may perform as an Overview Specialist, a Discipline Specialist or a Reviewer, but none of the latter three may perform as a Team Leader. An Overview Specialist may also perform as a Discipline Specialist or as a Reviewer, but neither of the latter two may perform as an Overview Specialist. A Discipline Specialist may also perform as a Reviewer, but a Reviewer may not per-form as a Discipline Specialist.

The professional degree or degrees held by each individual and the l primary areas of expertise of the individual are listed immediately after the individual's name. The number of years of experience in the nuclear industry of each individual and his or her years of professional level practice are listed in the columns titled " Professional Practice Years" and " Nuclear Experience Years." The number of years of pro-fessional practice is the total number of years the individual has prac-ticed his engineering disciplines. The number of years of nuclear experience is that portion of the professional practice during which the individual has practiced his engineering disciplines in the nuclear industry.

B-i

Professional Nuclear Practice Experience Name Years Years TEAM LEADER H. N. Bass, BS, Mechanical Engineering; 35 29 Mechanical Systems, Reactor Equipment, l Licensed Operator, Construction, Startup R. O. Brugge, BS, Physics; Core Physics, 35 35 Safety Analysis, Startup, Technical Specifications P. M. Clark, BS, Mechanical Engineering; 38 37 Mechanical Systems, Instrumentation and Control, Safety Analysis, Management S. B. Dalal, BS, Civil Engineering; 27 11  :

MS, Business Administration; i Civil / Structural, Cost Control, Scheduling, Contract Administration l 1

C. F. Falk, MS, Chemical Engineering; 41 32  ;

Radio Chemistry, Shielding, Waste  ;

Processing, Water Chemistry, Management '

L. Fitz, MS, Mechanical Engineering; 25 17  ;

Mechanical Systems, Piping, Radiation i Protection, Startup, Management i J. M. Healzer, PhD, Mechanical Engineering; 27 19 Mechanical Systems, Safety Analysis, Reactor Design, Stress Analysis, Management J. E. Hench, PhD, Mechanical Engineering; 23 23 Mechanical Systems, Safety Analysis, Instrumentation and Control, Electrical Systems, Management I. M. Jacobs, BS, Electrical Engineering; 41 30 Electrical Engineering, Instrumentation and Control, Mechanical Systems, Safety Analysis, i Management '

B-1

Professional Nuclear Practice Experience Name Years Years TEAM LEADER (Continued)

C. B. Johnson, BS, Mechanical Engineering; 26 21 Safety Analysis, Mechanical Systems, Instrumentation and Control, Equipment Design C. R. Jones, BS, Physics; Mechanical Systems, 34 30 Radiation Protection, Reactor Design, Equipment Design, Instrumentation and-Control, Civil Engineering, Management J. E. Kjemtrup, MS, Mechanical Engineering; 35 23 Mechanical Systems, Piping, Electrical Systems, Instrumentation and Control, Management A. H. Klose, MS, Mechanical Engineering; , 20 19 Mechanical Systems, Licensing, Safety Analysis, Management L. E. Minnick, BS, Mechanical Engineering; 37 31 Mechanical Systems, Reactor Design, Safety Analysis, Instrumentation and Control, Plant Operation, Management (Utility)

J. P. Neissel, PhD, Physics; Instrumentation 35 30 and Control, Mechanical Systems, Reactor Design, Electrical Systems, Management R. A. Petrokas, MS, Mechanical Engineering; 20 14 Mechanical Systems, Piping, Safety Analysis, Stress Analysis H. W. Pielage, MS, Electrical Engineering; 26 26 Electrical Systems, Instrumentation &

Control, Safety Analysis, Radiation Protection, Fire Protection J. G. Puls, MS, Physics; Mechanical Systems, 22 19 Safety Analysis, Electrical Systems, Instrumentation and Control, Reactor Design, Radiation Protection, Management B-2

l Professional Nuclear Practice Experience Name Years Years TEAM LEADER (Continued)

G. Roy, MS, Electrical Engineering; 40 36 Electrical Engineering, Mechanical Systems, Safety Analysis, Instrumentation and Control R. L. Shipp, BS, Metallurgy; -31 21 Metallurgy, Welding, Nondestructive Examinations, Stress Analysis R. Srinivasan, PhD, Civil Engineering; Piping, 12 6 Stress Analysis, Civil Engineering, Seismology, Management H. Sunners, BS, Chemical Engineering; 25 25 Chemical Engineering, Mechanical Engineering, Nuclear Engineering, Licensing, Instrumentation and Control,  ;

Quality Assurance, Management l G. Walke, MS, Public Health; Safety Analysis, 28 28  !

Health Physics, Meterology, Quality I Assurance, Management (Utility)

OVERVIEW SPECIALIST l J. J. Hogle, BS, Electrical Engineering; 43 29 l Instrumentation and Control, Electrical  !

Systems, Safety Analysis, Startup, j Management  ;

)

C. M. Kang, PhD, Nuclear Engineering; 14 14 l

, Mechanical Systems, Reactor Design, 1 Safety Analysis, Instrumentation and Control W. Michaels, MS, Mechanical Engineering; 13 12 Mechanical Systems, Reactor Design, Instrumentation and Control, Radiation Protection B-3

Professional Nuclear Practice Experience Name Years Years OVERVIEW SPECIALIST (Continued)

A. L. Ostenso, BS, Electrical Engineering; 15 15 Electrical Systems, Mechanical Systems, Instrumentation and Control, Safety Analysis M. R. Pamidi, PhD, Mechanical Engineering; 12 12 Mechanical Systems, Instrumentation and Control, Electrical Systems, Stress Analysis DISCIPLINE SPECIALIST R. D. Allen, MS, Mechanical Engineering; 17 17 Mechanical Systems, Equipment Qualification G. C. Brockmeier, BS, Civil Engineering; Civil, 40 30 Stress Analysis, Mechanical Systems, Management W. C. Cohn, MS, Mechanical Engineering; 30 17 Welding, Quality Assurance, Mechanical Systems, Equipment Design E. M. Duke, MS, Cybernetic:; 34 18 Nuclear Fuels, Welding, Chemical Processes, Quality Assurance A. O. Engler, MS, Engineering Science; 24 20 l Mechanical Systems, Radiation Effects, '

Safety Analysis M. Frankel, BS, Mechanical Engineering; 34- 28 Mechanical Systems, Equipment' Design, Licensing, Management T. Y. Fukushima, MS, Mechanical Engineering; 20 20 Safety Analysis, Instrumentation and Control, Management B-4

Professional Nuclear Practice Experience Name Years Years DISCIPLINE SPECIALIST (Continued)

W. S. Gibbons, BS, Metallurgy; 33 26 Metallurgy, Piping, Quality Assurance F. K. Herrick, BS, Mechanical Engineering; 33 29 Mechanical Systems, Reactor Design, Licensed Operator R. H. Jones, BS, Mechanical Engineering; 24 19 Mechanical Systems, Spent Fuel Shipping, Safety Analysis L. A. Keller, MS, Mechanical Engineering; 11 11 Mechanical Systems, Electrical Systems, Safety Analysis, Licensing R. E. Koppe, BS, Civil Engineering; Civil, 21 21 Seismology, Management R. E. Kuerzel, BS, Electrical Engineering; 33 19 Electrical Systems, Instrumentation &

Control, Mechanical Systems J. J. Lucas, BS, Nuclear Engineering; Safety 10 10 Analysis, Instrumentation and Control R. S. May, PhD, Nuclear Engineering; Safety 10 10 Analysis, Instrumentation and Control W. W. Palmer, BS, Electrica~1 Engineering; 37 17 Electrical Systems, Instrumentation and Control, Mechanical Systems, Management S. W. Smith, BS, Engineering; Equipment Design 13 13 and Test, Licensing i

l f

B-5

Professional Nuclear Practice Experience Name Years Years DISCIPLINE SPECIALIST (Continued)

K. Watkins, MS, Mechanical Engineering; 14 14 Nuclear Systems, Stress Antlysis,.

Reactor Design J. A. Woolley, MS, Nuclear Engineering; 20 20 Mechanical Systems, Equipment Design, Safety Analysis, Management REVIEWER D. Abdollahian, PhD, Mechanical Engineering; 6 6 Mechanical Systems R. A. Abdollahian, MS, Petroleum Engineering; 5 3 Mechanical Systems, Water Chemistry M. Bein, PhD, Mechanical Engineering; 22 10 Mechanical Systems, Safety Analysis, Instrumentation ano Control, Management R. Dormido, BS, Mechanical Engineering; 3 3 Mechanical Systems J. C. Gillis, PhD, Mechanical Engineering; 24 5 Mechanical Systems K. C. Kim, PhD, Nuclea. Engineering; 10 9 Nuclear Fuels, Radwaste, Computer Science l

V. Rapp, BS, Nuclear Engineering; Computer 7 5 Systems B-6

l l

1 I

l APPENDIX C l

Appendix C contains the official SLI Procedures for the Litigation Record Review Program which were issued pursuant to SLI's coatract with -

HL&P for the performance of the review. These Procedures set forth the basic requirements to be met by SLI during the review and governed the activities of all SLI participants in the review. These Procedures were supplemented by formal training sessions and written instructions and guidelines explaining details of how the Procedures were to be imple-mented.

l l

I C-1

Procedure No. LRP-1 Revision 4 Page 1 of 12 Date Issued FEB 181926  !

S. Levy Incorporated Review of HL&P v B&R Litigation Record Litigation Review Procedure - LRP-1 Suninary of Revisions l Revision No. Revision Description Rev. O Initial Issue Rev. 1 Change NRC Citing form Rev. 2 Added Sections 4.7, 4.8, 4.9 and 4.10. l Clarified Sections 5.2, 5.5.1, 5.5.6, 5.6, 5.7, 5.7.4, 5.7.6, Attachment 8.1, Attachment 8.2 and Attachment 8.3. l Added reverse side of DEF. I Revised Attachment 8.6.

Rev. 3 To ensure availability of computer records for decisions by Overview Specialists. i Clarified. -

Revised Attachment 8.4.

Added Attachment 8.7.

Rev. 4 Clarified duties of Overview Specialist Revised Attachment 8.6 and 8.7 Revision Authorization Date Revision No. 4 Date Issued h i

. FEB 181926  ;

Approved by (SLI)

Approved by j (SLI QA) 2./ g Approved by HL&P Nuclear y P

' ' l i j Licensing h y/gjg( '

Approved by (HL&P -

Nuclear Assurance)

(f l/V l

l l

l Procedure No. LRP-1 l Revision 4 i Page 2 of 12 '

Date Issued FEB 18 1096 S. Levy Incorporated 1

Title:

Review of HL&P v. B&R Litigation Record

Subject:

Litigation Review Procedure 1.0 PURPOSE To establish a procedure for reviewing the relevant portions of the litigation record in HL&P v. BAR to determine whether the record contains information about any previously unidentified safety-related deficiencies in the design or construction of the STP systems, structures or components.

2.0 SCOPE '

This Litigation Review Procedure applies to all reviews conducted 2

by tne Litigation Review Team of the portions of the litigation record designated for review. See Procedure LRP-2, " Materials to be Reviewed," for a complete list of materials to be reviewed.

~

3.0 REFERENCE DOCUMENTS HL&P Procedure PLP-02 4.0 RESPONSIBILITIES PANEL OF THE LITIGATICN REVIEW TEAM AND SENIOR ADVISORY 4.1 Litigation Review Team Members The Litigation Review Team members will consist of SLI employees and subcontractors and will include Reviewers, Discipline Specialists, Overview Specialists and a Team Leader and his designees.

4.2 Reviewers i

Review every line of deposition transcripts, expert reports and "

interrogatory answers listed in Procedure LRP-2. Prepare an 8t* N Assertion Form for each assertion made by witnesses or parties con ~- '-

cerning deficiencies in the STP systems, structures or components J

Procedure No. LRP-1 Revision 4 Page 3 of 12 Date Issued FEB 181926 (SSC) as designed or constructed. Assign category designation to each assertion by a witness or party to permit sorting by subject matter. Review computerized listing to assure that the description j and categorizations have been correctly entered into the litigation review data base. In addition, prepare a list of all places in the reviewed materials where the witness or party described or charac- ,

terized the Nuclear Regulatory Commission's practices, policies, '

personnel capability, or attitude, i 4.3 D_iscipline Specialists

{

Review all Assertion Forms in category assigned to Discipline Specialist. Determine whether statements appearing on Assertion Forms in fact meet the Criteria for Identification of Assertions. d 1

Disposition the remaining assertions by determination that (1) it Di is not safety-related; (2) it has been previously identified for  !

resolution or resolved in STP documentation; or (3) it is factually erroneous. Complete a Deficiency Evaluation Form for any asser- "

tions not disposed of by the above means. Review computerized i listings to assure that the product of the Discipline Specialist's j work has been correctly entered into the litigation review data base. Discipline Specialists should consult other Discipline Specialists or Overview Specialists to resolve potential inter-disciplinary concerns.

4.4 Overview Specialists l Review all statements that Discipline Specialists have determined do not meet the criteria for assertions of deficiency to ensure that this determination is correct. If the statement should have been disposed of as an assertion of deficiency, return it to the Discipline Specialists for disposition. Review all assertions determined not to be safety-related for possible systems interac-tion or interdisciplinary concerns. Where such concerns are pre-sent, a committee of Overview Specialists determines whether, in 1 light of these concerns, the assertion can still be disposed of as not safety-related. If any member of the comittee has a concern Ry N that a safety system might be affected, dispose of assertion by demonstrating (1) that it has been identified for resolution or resolved in STP documentation; or (2) that it is factually erro-neous. If the assertion cannot be disposed of by one of the above methods, prepare a Deficiency Evaluation Form for that assertion. ,

Review computerized listings to assure that the product of the  !

i Overview Specialist's work has been correctly entered into the l

litigation review data base. Overview Specialists should consult .-

I

Procedure No. LRP-1 Revision 4 Page 4 of 12 Date Issued FEB 181926 other Overview Specialists, Discipline Specialists or the Team Leader to maintain awareness of the various types of asserted defi-ciencies being examined during the review process and to resolve potential interdisciplinary concerns.

4.5 Team Leader Develop and maintain procedures, guidelines, data base, schedules, work assignments and ad.ninistrative records.

Select, train and supervise Reviewers, Discipline Specialists. l Overview Specialists and any Team Leader designees assigned to assist the Team Leader.

Assign material to be reviewed or dispositioned to appropriate Reviewers, Discipin e Specialists, and Overview Specialists.

Have qualified personnel perform periodic reviews of Reviewer,  !

Discipline Specialist, and Overvier Specialist work. Maintain cri-teria for these reviews and objective evidence of the reviews. l i

The Team Leader has authority to reassign documents for review, t.o require additional reviews, ta :orrect errors in the preparation'of review documents and to order that any work being performed be halted.

Review and transmit Deficiency Evaluation Forms to the HL&P STP Engineering Manager, for all assertions of safety-related deficien-cies which cannot be shcwn to have been identified by the STP for resolution or to be factually erroneous.

l Maintain files of all forms generated during litigation review pro-cess.

4.6 Senior Advisory Panel Monitor litigation review progress. Perform such other reviews as necessary to assure that the litigation review program is being conducted in a manner consistent with its objectives and proce-dures. After completion of litigation review process and examina-tion of final report, prepare statement containing Senior Advisory Panel's conclusions as to whether the litigation review has met its objectives.

l Procedure No. LRP-1 Revision 4 Page 5 of 12 Date Issued FEB 181956 4.7 Disposition Leader Plan, coordinate and direct' Squad Leaders in the dispositioning process. He is appointed by the Team Leader. He prepares detailed memoranda or instructions in conformance with the Project Plan Procedures and Guidelines for approval by the Team Leader. He is specifically authorized to change, modify, add and delete the sta-tus designations used on the Disposition Forms.

4.8 Disposition Specialist Squad Leaders Squad Leaders are individually responsible for the finished work of their Squad and sign-off of their work. They may delegate this resprosibility only to individuals in their Squad and only with the prior written approval of the Disposition Leader and the Team Leader. Furthermore, they and their designees must be qualified as

' Discipline Specialists (See 6.2 of LRP-1). Squad Leaders are appointed by the Disposition Leader with the approval of the Team Leader.

4.9 Overview Specialist Squad Leaders Squad leaders are individually responsible for the finished work of their Squad and sign-off of their work. They may delegate this responsibility only to individuals in their Squad and only with the prior written approval of the Disposition Leader and the Team Leader. Furthermore, they and their resignees must be qualified as Overview Specialists (See 6.2 of LRP-1). Squad Leaders are appointed by the Disposition Leader with the approval of the Team Leader.

4.10 Disposition Control Leader Tracks and reports disposition progress. He is appointed by the Team Leader.

4.11 Squad Staff The Squad Staff is appointed by the Disposition Leader and reports to the assigned Squad Leader. Their function is to assist the Squad Leader in his duties.

_ _ ~ . ._ . . _ __ __ _ _

Procedure No. LRP-1

. Revision 4 Page 6 of 12 Date Issued FEB 181M6 i

l

-5.0 REQUIREMENTS 5.1 The Team Leader will assign each Reviewer depositions, expert report sections, and interrogatory answers from the list in Procedure LRP-2 which have been grouped by subject matter. General subject groupings will be those shown in LRP-3, " Subject

Groupings."

J 5.2 The Reviewer shall review every line of each assigned deposition.

expert report section, and interrogatory answer and record every assertion made by a witness or party concerning deficiencies in STP specific SSCs as designed or constructed. As he-reads, he will

} make notations in the margin as to the subject matter of the j material he is reading. For the purpose of this review, a defi-j ciency is defined as a defect which will or may impair the ability ,

i j

of an SSC to perform its intended function. Deficiencies may exist in the SSC itself, in its associated design documents (e.g., calcu-i lations,-drawings or specifications) or in documents establishing the quality of SSC (e.g. QA/QC documentation). (See " Criteria for Identification of Assertions of Deficiency" in Attachment 8.1) In i

reviewing deposition transcripts, the Reviewer shall refer to any deposition exhibits necessary to understanding the assertions in 3

the transcripts. Each assertion shall be recorded on an Assertion i

Form (Attachment 8.2). The Reviewer shall assign a category i

designation to each assertion. The list of category designations is provided in LRP-3, " Subject Groupings." Assertions given spe-j cial categories such as "XXXX" and "AAAA" will be referred to the Team Leader for further processing.

E In addition, the Reviewer shall prepare a list of all places in the

{ deposition, expert report or interrogatory answer where the witness or party judgmentally described or characterized the Nuclear'

)! Regulatory Conunission's practices, policies, personnel . capability, or attitude. This list will be recorded on NRC Citings Forms (Attachment 8.3).

4 The Reviewer shall have the content of the forms he prepared

! entered data baseinto output. the data base and verify correct entry by signing the 5.3 A member of the Litigation Review Team shall have all assertions l

and category designations compiled and sorted by category designa-tion.

i 5.4 The Team Leader shall assign categories of assertions to Discipline

! Specialists according to their respective disciplines.

i

. , _ _ _ _ . - _ . . - _ _ . _ - _ - ~ . _ _ - , _ _ . _ . . - - _ _ . _ . _ _ _ _ _ _ , . _ _ _ . . . _ _ . . _ . _ _ _ _ , . _

Procedure No. LRP-1 Revision 4 Page 7 of 12 Date Issued FEB 18 M26 5.5 The Discipline Specialist shall review each assertion and the respective portions of the reviewed material as may be necessary to fully understand the assertion.

5.5.1 The Discipline Specialist shall group assertions susceptible'to the same disposition ogether for a single disposition. For any ,

statement recorded on an Assertion Form which the Discipline l Specialist determines does not meet the " Criteria for Identification of Assertions of Deficiency," the Discipline Specialist shall prepare a Disposition Form documenting his determination and explaining why the statement does not meet these criteria. The Discipline Specialist performs no further action with respect to statements he has determined not to be 1 assertions ~ deficiency.

5.5.2 For each assertion or group of identical assertions, the i

Discipline Specialist shall determine whether they are safety-related by determining whether the SSC involved has been 3 classified by STP as safety-related. (See~" Criteria for Safety Determination" in Attachment 8.1.)

5.5.3 For each assertion the Discipline Specialist determines is not safety-related, the Discipline Specialist shall record his deter-mination and the basis for it on the Disposition Form in

' Attachment 8.4. The Discipline Specialist performs no further reviews or evaluations of assertions he has determined not to be safety-related.

5.5.4 For each assertion the Discipline Specialist has determined to be safety-related, the Discipline Specialist shall identify the STP documentation that in6 cates that the substance of the assertion has been resolved, is being resolved or has been identified for resolution by the "' ;See " Criteria for Demonstrating STP Identification" in .".tv nent 8.1.) References to such STP docu-mentation will be recorded on the Disposition Form in Attachment 8.4. The Discipline Specialist performs no further reviews or i

evaluations of assertions for which STP documentation indicates STP identification of the item for resolution.

5.5.5 Any assertions for which the Discipline Specialist cannot find STP documentation indicating that the STP has identified the item for resolution must be further reviewed to determine whether the assertion is factually erronecus. This determination must be based on STP documentation that describes the SSC and provides positive evidence that the assertion is factually erroneous.

l Procedure No. LRP-1 Revision 4 Page 8 of 12 Date Issued FEB 1 8 1936 (See " Criteria for Deter 1nination on Factual Basis" in Attachment 8.1.) If the Discipline Specialist determines that an assertion

~is factually erroneous, he must document the basis for the deter-mination and reference the STP documentation used in making the determination on tha Disposition Form in Attachment 8.4. )

5.5.6 For any assertions that were not dispositioned under 5.5.3, i 5.5.4, or 5.5.5 above, the Discipline Specialist shall prepare a  ;

Deficiency Evaluation Form (DEF) (Attachment 8.5) in accordance l with the instructions in Attachment 8.5, and transmit it to the i Team Leader. The Team Leader shall review each DEF to ensure l that it is correctly prepared and to maintain cognizance of the l types of potential deficiencies being identified to the STP.  !

After review, the Team Leader shall send the DEF to the HL&P STP 4

Engineering Manager, for STP evaluation.

l 5.5.7 The Discipline Specialist shall have the content of the forms he prepared entered into the data base and verify correct entry by {

signing the data base output.

5.6 The Team Leader shall assign all of the assertions the Discipline Specialists have determined not to be safety-related to the

Overview Specialists. In additiont the Team Leader shall assign

4 all statements recorded by Reviewers which were later determined by a Discipline Specialist not to be assertions of deficiency to the Overview Specialists.

5.7 The Overview Specialist shall review each assigned assertion or statement the Discipline Specialist has determined not to be an assertion of deficiency and the respective portior. of the reviewed materials as may be necessary to understand the tesertion or state-ment. '

~

5.7.1 The Overview Specialist shall evaluate the substance of each l assertion determined not to be safety-related by a Discipline Specialist to determine whether the assertion presents possible interdisciplinary or systems interaction concerns. The Overview Specialist shall document the final classification on the Overview Disposition Form in Attachment 8.7.

i 5.7.2 If assertions have 5een determined to have potential inter-Rev.'

disciplinary or systems interaction, they shall be further eval-uated by a committee of Overview Specialists to determine whether, considering possible systems interaction or inter-disciplinary concerns, the assertion is safety-related, using the ..

4 Procedure No. LPP-1 1

Revision 4 Page 9 of 12 Date Issued E i

" Criteria for Safety Determination" in Attachment 8.1. If it is g,4 determined that the assertion is not safety-related, the asser- .-

tion shall be documented as NS on the Overview Disposition form in Attachment 8.7 and no further review shall be conducted of

, that particular assertion.-

5.7.3 All assertions that the committee of Overy'ew Specialists has j ' determined may possibly affect the operation of a safety system i

will be further evaluated using the " Criteria for Demonstrating by, (

STP Identification" and the " Criteria for Determination on .-

i Factual Basis" in Attachment 8.1. The Overview Specialist will follow the procedures for assertion disposition using these cri-teria as described in Sections 5.5.4 and 5.5.5, but shall record

{ his decisions on the Overview Disposition Form, Attachment 8.7.

l 5.7.4 The Overview Specialist shall examine each statement that the Discipline Specialist has determined does not meet the " Criteria for Identification of Assertions of Deficiency." Applying the 4

" Criteria for Identification of Assertions of Deficiency," the Overview Specialist shall determine whether the statement should have been recorded by the Reviewer. If the Overview Specialist concurs with the Discipline Specialist that the statement does not meet the " Criteria for Identification of Assertions of ,

} Deficiency," the Overview Speciali t shall record this deter- )

i mination on the Disposition Form in Attachment 8'.4 and no further .. i l

i review of the statement will be conducted. If the Overview '

)

Specialist determines that the statement was properly recorded as .

1 an assertion of deficiency by the Reviewer, he will return it to 9JW 1

the Discipline Specialists for disposition as an assertion of l deficiency. .. 3 I

i

! 5.7.5 For any assertions that were not disnositioned under sections  !

! 5.7.1, 5.7.2 or 5.7.3 above, the 0<er view Specialist shall pre- )

pare a Deficiency Evaluation Form (DEF) (Attachment 8.5) and i  ;

i transmit it to the Team Leader. The Team Leader shall review-  ;

each DEF to ensure that it is correctly prepared and to maintain cognizance of the types of potential deficiencies being iden-tified to the STP. After review, the Team Leader shall send the

! DEF to the HL&P STP Engineering Managar for STP evaluation.

l 5.7.6 Any statement recorded on an Assertion Form that a Discipline i

Specialist dispositions as not meetine the " Criteria for Identification of Assertions of Deficiancy " but that an Overview Specialist subsequently determines is an assertion of deficiency

' under these criteria shall be reassign 1d to the Discipline l

L

Procedure No. LRP-1 Revision 4 '

Page 10 of 12 Date Issued FEB 181996 Specialist by the Team Leader for disposi.tioning pursuant to Sections 5.2 through 5.10 of this Procedure.

5.7.7 The Overview Specialist shall have the content of the forms he prepared entered into the data base and verify correct entry by  !

signing the data base output.

l 5.8 A member of the Litigation Review Team shall compile all input

information generated by all of the Discipline Specialists and all 1

of the Overview Specialists.

5.9 A flow chart depicting the review and disposition activities is  ;

j enclosed as Attachment 8.6. '

5.10 The Team Leader shall be responsible for assembling and reviewing the information generated as a result of all review activities and producing a report summarizing the results of the review of the HL&P v. BAR litigation record.

i 6.0 LITIGATION REVIEW PROGRAM CONTROLS AND QUALITY ASSURANCE 1

1 6.1 Method To Be Employed

The Litigation Review Program will be conducted in accordance with j

the S. Levy Incorporated Quality Assurance Program Manual, Revision 1, dated 9/1/83 and the Project Plar.

i The overall plan for assuring the quality of the team's work begins with the selection of members with appropriate qualifications and assignment of tasks commensurate with those qualifications.

Secondly, training will be provided. Each member will be provided with written procedures, guidelines and samples of work products.

and an orientation and training session will be mandatory for each l participant. The Team Leader or his designees will perform i

periodic reviews of each member's work to monitor work in progress.

6.2 Team Member Qualification and Assignment 1

i i

The qualifications of each engineer on the Litigation Review Team i will be evaluated against a written set of criteria. Basic minimum qualifications for the engineers are as follows: Reviewer - three (3) years of engineering experience in his disef oline; Discipline Specialist - seven (7) years of experience in his' respective i

i discipline on nuclear plant engineering, design or constr1ction; i

I i

i , , _ . . _ . . . , . _ _ . . . , . _ _ . . ~ , , . _ , . . _ . ,

- , . _ . _ . _ . _ , _ . . . _ _ . . , _ . - . , _ . ~ , . _ _ , _ _ _ _ , , _ . . . . . . - _ _ , . . . _ _ _ _ , . , _ . .

Procedure No. LRP-1 Revision 4 Page 11 of 12 Date Issued FEB 181996 l

l I

Overview Specialist - ten (10) years of experience doing multi-  !

disciplinary work or oversteing engineering work in different disciplines on nuclear plants; and Team Leader or Team Leader's designee - ten (10) years of technical management experience in nuclear plant engineering design or construction. Based on this evaluation, each engineer will be identified as qualified for the position of Reviewer, Discipline Specialist, Overview Specialist, or Team Leader. Multiple qualifications will be permitted.

Evidence of assignments made during this review will be maintained.

Assignments will be made in accordance with the team members' edu-cation and experience.

6.3 Training i

Each team member will receive a training manual containing proce-dures, instructions, and guidelines. During the course of the review nrocess, he will place in it any revisions to procedures and instructions that are issued. The Litigation Review Team members )

will refer to their training manuals for guidance during the course of their work.

1 Each team member will attend an orientation and training session j where the contents of the manual will be presented and explained.  ;

Objective evidence of orientation and training session attendance 1 and the subject matter covered at the session will be maintained. 1 6.4 Team Leader Review of Work Product i l

The work of each Reviewer, Discipline Specialist, and Overview Specialist will be periodically reviewed by the Team Leader and designees of the Team Leader. These reviews will be performed in conformance with written criteria, and objective evidence of the review will be maintained.

6.5 Quality Assurance The S. Levy Inc., Corporate QA Manager will appoint a QA specialist to assist him in assuring that.the litigation review program is conducted in accordance with the HL&P-SLI contract and SLI QA

! Program requirements. SLI QA will conduct surveillances reviews, and audits of the litigation review work to assure review team compliance with the Litigation Review Procedures. All SLI QA acti-vities will be conducted by personnel who are not responsible for any of the litigation review work.

i

- - v -i. _ - - , .m -g.-

Procedure No. LRP-1 Revision 4 Page 12 of 12 FEB 181926 Date Issued 7.0 DDCUMENTATION 7.1 Litigation Review Forms (Attachments 8.2, 8.3, 8.4)

These forms, when complete, shall be filed in the Record Center.

They will be securely fastened into binders or placed into folders in metal cabinets, along with the copies of the material reviewed and marked by the Reviewers.

7.2 Records Retention Upon conclusion of the project, all records will be forwarded to the Houston Lighting and Power Company.

8.0 ATTACHMENTS 8.1 Criteria 8.2 Assertion Form 8.3 NRC Citings Form 8.4 Disposition Form 8.5 Deficiency Evaluation Form (DEF) 8.6 Litigation Review Flow Chart 4

8.7 Overview Disposition Form 1

\

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-r , - c- ~ , - -

1 l

1 LRP-1 Attachment 8.1 Page 1 Rev.4 FEB 181986 CRITERIA FOR IDENTIFICATION OF ASSERTIONS OF DEFICIENCY ,

1 In order to be recorded, an assertion must sati.fy each of the following criteria:

1. The assertion must pertain to at least one of the following or to their associated design or quality control documents:

1 1.1 STP systems, structures, or components (SSC).

1.2 Classes of STP SSC (such as valves, reinforced concrete walls, electric systems).

1.3 Processes relating to specific STP SSCs (such as welding, coatings).

1.4 The overall STP site (data or studies on meteorology, seismo-logy, demographics, etc.).

2. The assertion must either:

4 (a) Describe a deficiency. A deficiency is a defect which will or may impair the ability of an SSC to perform its intended func-tion; or (b) If the assertion does not include any specific deficiency, as defined under (a), it must pertain to documents providing objective evidence of the quality of design or construction for specific SSCs at STP. (Absence of calculations for system X, lack of verification documents for component Y, incomplete Q/C records for weld N, etc.)

3. The assertion must satisfy one of the following criteria:

3.1 It was made by a witness in a deposition.

3.2 It was confirmed by a witness accepting a statentent by a lawyer. I i

3.3 It was included in an expert report. l 3.4 It was made by a party in an interrogatory answer.  !

l l

1 l

LRP-1 Attachment 8.1 ,

Page 2 Rev. 4 FEB 181936 CRITERIA FOR SAFETY DETERMINATION

1. An assertion of deficiency that involves system (s), structure (s) or component (s) which have been classified by the South Texas Project as one of the following is a safety-related assertion:

Safety Class 1 Safety Class 2 Safety Class 3 Class lE Seismic Category 1 4

2. An assertion of deficiency that involves system (s), structure (s) or component (s) that are listed in the STP FSAR Section 3.2 or in the Bechtel Energy Corporation Design Criteria for the South Texas Project as safety-related items is a safety-related assertion.

3. An assertion of deficiency that involves system (s), structure (s) or component (s) with a Total Plant Numbering System (TFNS) number that designates a safety-related item (1, 2, 3, 4 or 5) is a safety-related assertion.

4 l

LRP-1 .

l Attachment 8.1 )

. Page 3 Rev. 4 FEB 181996 '

)

CRITERIA FOR DEMONSTRATING STP IDENTIFICATION .

I l

1. The STP documents cited by the Specialist as evidence of prior i identification of the substance of an assertion by the STP must i completely cover the specific assertion of deficiency. l l

2. The STP documents cited by the Specialist must show:

! a. That the deficiency asserted has been corrected; l or l

b. That the deficiency asserted is in the process of being corrected; or

c. That the deficiency asserted has been identified for l resolution. i

3. Documents cited as reflecting corrective action or identification for resolution of the asserted deficiency must appear on the list gaty,1L

)

of documents approved for reference on Disposition Forms.

~~

4. The reasons why STP documentation shows adequate identification or corrective action must be clearly stated by the Specialist.

l 1

l

\

LRP-1 .

Attachment 8.1 Page 4 Rev. 4 FEB is Iggg f I

CRITERIA FOR DETERMINATION ON FACTUAL BASIS 1

1. STP documentation must provide positive evidence showing the asser-tion to be factually erroneous. Unless STP documentation provides i such positive evidence, the Specialist may not classify the asser-tion as factually erroneous.

2. The referenced STP documentation must describe the system, struc-ture, or component as designed or constructed at or after the time the deficiency is asserted to have existed.

3. The reasons why the documentation shows the assertion to be fac-tually erroneous must be clearly articulated by the Specialist.

i e

1 l

1 1

LRP-1  !

Attachment 8.1 l P9 5 FEB 181926 e

)

CRITERIA FOR INTERDISCIPLINARY AND SYSTEMS INTERACTION

DETERMINATION

1. An assertion of deficiency that involves disciplines other than that of the Discipline Specialist who initially determined that f2j4/, y, the substance of the assertion is not safety-related must be i

reviewed by the Overview Specialist to determine whether it is safety-related. ..

i

2. An assertion of deficiency that involves system (s), structure (s),

or components (SSC) other than those considered by the Discipline Specialist in his initial disposition of the assertion as not safety-related must be reviewed by the Overview Specialist to determine whether it is safety-related.

3. If the SSC considered by the Discipline Specialist shares a com-ponent or a process or has physical supporting connections to another SSC, the assertion must be reviewed by the Overview Specialist to determine whether it is safety-related.

4. If the functional or physical failure of the SSC considered by the Discipline Specialist in dispositioning an assertion could propa-gate to other SSCs the assertion must be reviewed by the Overview  :

Specialist to determine whether it is safety-related.

l

7

. , s.;

LRP-1 ,

Attachment 8.2 Rev. 4 FEB 181996 STP LITIGATION REVIEW ASSERTION Document No. Document

Title:

l Assertion No. Category _

Designators Reviewer Name: ,

l Date Completed: ,

Reviewer Signature v l

3 Document Date: _

Deposition Volume No. I I

Page No./Line Nos. ASSERTION i

l l

l 4

I Updated: Disposition No.

1 Form No. ASRT-01 Overview Disposition No. l I

I i

- . _ . -- . _ _ _ . _ . _ . _ - _._._J__,.

l l

LRP-1 Attachment 8.3 Rev. 4 Issue Date: FEB 181326 1

- j

^

STP LITIGATION REVIEW NRC CITINGS Document No.: Document

Title:

Date Completed: Page of Revision No.:

1 Reviewer Name:

Reviewer Signature l

i Sequence Vol. No. or Deposition Page No./  ;

j No. Section No. Date* Line Nos. j i

l I

l l

l j

l l

l l

l l

l 1

l l

i l

1 l

Updated: l Form No. CIT-03 */ Computer Entry l

l

_ _ . . . .. _ ~ - . - _ _ _-.

b

. LRP-1 Attachment 8.4 Rev. 4 Date Issued: FEB 181036 s

STP LITIGATION REVIEW

~ DISPOSITION

^

Document No./ .~

Assertion No. : -

(ex:0001-016) <

.~

Disposition No: Disposition:

Categories t

Specialist Name: _ Status:

Specialist Signature STP Reference DISPOSITION y ^ ': ,

'waF 1

Updated.

Form No. 015-02 IM '

S

&Y A,i g I

? . : .. .

1 l

, LRP-1 Attachment 8.5 '

Rev. 4 l Page 1 FEB 181926 OtFeOtteCV tv4LUATMps P0ans its peamm af se Fem b o pudes e mushadun tw IEAP engdevas to hemisfy to W amuseus asummme a to amuseums a Duannulm, *

,, g pwmes as PLP-43. Tk beim shamed ghe a e-gemas a damagelse a m uns asseand emme e g DATEREMr#ES A8'umf h Sassey Gam af Cassemuut Seismis Ceegory of 8*- W Omiyi Dammemum l w Sra==la Omsdan Srimmie Seweme lalb-sum ltdt 9 ,M Chs. 8 500 last 2 BC-3 sema Cas. I SPEC.

8m thee SC-3 OTHEE E

[-)

h miCamyswit, Symmm e Sewess a sanaase a sie Canen.

Ehmuripsum af Candese:

Deze Damment i

DEFlevtaae gg ,

FttvaluaTetys:

] RafetolaC RaferW a lac om ame w. h M Osa i i

teamacte tbGimseasang l

Rafur n 84C I

' \

ase.rw i seew m, mm-s, Ones, , i enAMActs h so me ene.

1

LRP-1 Attachment 8.5 Rev. 4 Page 2 FEB 181986 LINE NO. INSTRUCTION 1 The responsible SPE should assign and record form and revision number; enter date report received.

2 Record the unit number (s) affected. Recor.d the safety class and seismic category of the system, structure, or component.

3 Give a brief description of how the deficiency was discovered.

Reference any deficiency related documents. ,

4 Record the title of the governing documents.

5 Record the requirement stated in the governing documents. ,

6 Describe the deviation and hazard as accurately and completely as possible.

~~

7 Signature of the initiator and the d' ate the form was prepared.

8 The SPE marks the appropriate "yes" or "no" block, signs and dates the DEF. Provide a short discussion of the basis for the detemination. Distribution is made in accordance with Section 6.2.

The Manager , Engineering, marks thi appropriate "yes 'i or I no '" '

9 ~

block, signs and dates the DEF. Provide a short discussion of 1 the basis for the determination. The Manager, Engineering may simply concur 'with the reason provided by the SPE. .

Distribution is made in accordance with Section 6.4.

• Steps 2 through 7 apply to DEF originator.

a LITIGAflGs REveE3 FLOW Osaat LRP-1 Cat.pris.,e ositions.

r.oort s.c ions, interrog. tor, ens. ors.

one Attachment 8.6 (TL)

Rev. 4 l FEB 181986 Assign Categorises esterial to revlemer. (TL)

I Amed revlee eterial one recore all essertiene of deficiency In engr. and const, of -

STP. (4)

I Assiga groups of essertions to Olscipline Specialist by category.

(TL) m-Do.s the stet en, recordes by tne nevle.er east tne acriterle for Does the statement recorose by tee Revle er no Identification of ' meet the aCetteria for scentification of Assertion of Deflefonev a Assertion of Defictency" (see LRP.13 (see LAP 1). (DS) (OS) 3 ves hQM .

yes no Y'A Group together Assertions g enet lone tnomselves to Reassign essertion END a

tne seen Dispositlen. (0$ to Discleline Spectatist. (TL) f h

is tne essertion of Assign groups of eeficiency safety. no relateel (DS) essertions to Overvler Specialist. (TL) s' 4

is enere project teentify project cocumentation on the yes Caos essertion in.

substance of tne

... mec.e ntation teet volve more then one ]

essortion? (05) ocorosses substance elscletine. systee, no _ END of essertion. (DS) structure, or componenti (05) no h E,.

,es is essertion factually toontify project erroneousf Consleering tne Inter.

(Q$)

socumentation show. elsciplinary nature ao _ END Ing essertion to be of essertion is it factually erroneous. safety-relatest (05) no or g don't know Y yes END h opers DEF. (DS) le there project leontify project eecueentation e yes docuamatetion substance of the that eferesses essertlan? (05) subject of asser.

tron. (Ost Review one sene no <

DEF to STP, ifL) 1 14 u

is essertion fact.

ustly erroneous? leentify project (05) E

~

secuentation E9 shoulag essertion to be factually no or erre eous (0$3

> een 't ano.

Propero DEF. (05)

Leesas for Activity Responsibi t tty END TL Teen Leeeer R Asvlewer 05 Discipline $seclettst 0$ Overvios Specialist to T. L)

END

LRP-1' STP LITIGATION REVIEW Attachmsnt 8.7 i OVERVIEW DISPOSITION Rev. 4 I

---

Date Issued FEB 1819,:0 Document No./ A Assertion No. :

1 I

Overview Disposition Disposition No: Categories :

Overview I Specialist Name : Status :

l w

---

Date Completed :

Overview Specialist Signature 4 k,

STP Reference Disposition l

i V  !

l l

l l

l l

Updated:

Fcrzt No. DIS-03

i Procedure No. LRP-2 l Revision 2 i Page 1 of 49 l l

Date Issued FEB 18195 S. Levy Incorporated l

1 Review of HL&P v B&R Litigation Record l Materials to be Reviewed - LRP-2 I

Sumary of Revisions 1

Revision No. Revision Description Rev. O Initial Issue Rev. 1 Scope of Work Update. Attachment 1 is a completely revised submittal.

Rev. 2 Corrections to pages 14, 15, 30 and 32 of Attachment 1 Revision Authorization Date Revision No. 2 Date Issued FEB 18192G r\ -

Approved by (SLI).

hg/rfg; Mili d d  %/u L/ -

Approved by (HL&P /

Nuclear Licensing) 9.fl f 8(e Approved by (HL&P ^

j b Nuclear Assurance) . -

2/

I

/

I I I

~=

Procedure No. LRP-2 l Revision 2 l Page 2 of 49 Date Issued FEB 1819:G

\

I S. Levy Incorporated '

Title:

Review of HL&P v. B&R Litigation Record

Subject:

Materials to be Reviewed Attachment 1 is a list of the material to be reviewed. It has been divided into the following sections:

I. Depositions i

IA. Bechtel Written Responses to B&R's Ninth Set of Interrogatories  !

1 1

II. Expert Reports III. Interrogatory Answers

l l

l Procedure No. LRP-2  !

Revision 2 Page 3 of 49 l Date Issued FEB 181;c3 HL&P v. B&R Litigation Record Material to be Reviewed l

l I. . DEPOSITIONS Section I consists of the oral aeposition transcripts to be reviewed.

l l

I l

l

a ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 4 of 49 FEB 18'":::'

Date Issued:

DEPONENT'S NAME VOLUME DEPO DATE ALEXANDER, Dennis Homer I 12/20/83 II 12/21/83 12/22/83 III IV 02/14/84 ALFORD, Richard Thomas I 01/23/85 II 01/29/85 ]

ALKOV, Frank L. I 09/05/84 II 09/06/84 ALLEN, Charles Richard I 12/11/84 AMARAL, John M. I 10/09/84 II 10/10/84 III 20/11/84 ANDERSON, Donald L., Jr. I 01/15/85 II 01/16/85 l l

ANGST, Gregory A. I 12/17/84 II 12/18/84 ASBECK, Frank D. I 02/12/85 II 02/13/85 III 02/14/85 IV 02/15/85 V 02/18/85 VI 02/19/85 VII 02/22/35 VIII 02/25/85 AUSTIN, Harry G. I 10/04/84 II 10/05/84 AYRES, John I 02/28/84 II 02/29/84 III 03/01/84' IV 07/10/84 V 07/11/84 VI 07/12/84

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 5 of 49 Date Issued: FEB 10 gg3 DEPONENT'S NAME VOLUME DEPO DATE BAKER, Hamilton L. I 01/17/85 BAZOR, James C. . I 02/13/84 II -

02/14/84 III 07/10/84 BEAVERS, Alan R. I 03/13/84 II 03/14/84 BIERMAN, George I 03/26/84 II 03/27/84 III 03/28/84 IV 03/29/84 V 03/30/84 VI 04/02/84 VII 04/03/84 VIII 04/04/84 IX 04/05/84- l X 04/06/84 I BISHOP, James Ketchel I 01/19/84 II 01/20/84 BOSQUEZ, Ted B. I 08/01/84 BRAUN, George I . 04/10/84 II 04/11/84 III 04/12/84

, BRISKIN, Joseph W. I 01/29/85 II 01/30/85 III 01/31/85 IV 02/01/85 BROGM, Knox M., Jr. I 08/22/84 II 08/23/84 III 08/24/84 IV 08/30/84 V 08/31/84 i

VI 09/18/84 VII 09/19/84 VIII 09/24/84 i IX 09/26/84

, . . . . . . - , - - . , , , ,--n , ~ . . , - - - , , - . , ,,..-~,...---a,

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 6 of 49 Dhte-Issued: FEB 181;4 DEPONENT'S NAME VOLUME DEPO DAIK BURFORD, Francis Gerard I 11/13/84 II 11/14/84 III 11/15/84 COMMANDER, Boyd I 01/12/84 II 01/13/84 l

COOPER, Gary D. I 02/27/84 II 02/28/84 III 02/29/84 IV 03/01/84 I v 03/02/84 1

VI 05/02/84 VII 05/03/84 VIII 05/08/84 I 04/23/85 II 04/24/85 COOPER / JORDAN / GRIMES I 06/26/84 II 06/27/84 III 06/28/84 IV 06/29/84 v 07/17/84 VI 07/18/84 VII 07/19/84 VIII 07/26/84 CORCORAN, Roy W.

I 12/05/83 II 12/06/83 l

COSCIA, Gerard I 09/13/84  !

II 10/30/84 l CRAIG, J. David 4

I 02/22/84 l CRANE, Carl Leroy I 10/27/83 II 05/09/84 III 05/10/84 IV 05/11/84 I 10/10/84 ENGLISH, Leon K.

' I 01/25/85 II 04/01/85 l III 04/16/85 '

ATTACHMENT 1 '

Procedure No. LRP-2 Revision 2-. 1 Page 7 of 49  !

Date Issued: FEB 18 Igig i 1

DEPCNENT'S NAME VOLUME DEPO DATE l ENGLISH, Leon K. (Cont'd) IV 04/30/85 FAWCETT, Ronald I 04/30/84 II 05/01/84  !

III 05/02/84 '

IV 05/03/84 V 12/18/84 VI 12/19/84 VII 12/20/84-FISHER, Gerald Lee I 11/01/83 II 11/02/83 III 11/03/83 IV 11/04/83 V 11/07/83 VI 11/08/83 VII 11/09/83' VIII '

11/10/83 IX 11/11/83 I(P.O.6010) 09/25/84 I(P.O.4012) 09/25/84 FLIPPO, Jack Lloyd I 01/21/85 II 01/22/85 III 01/23/85 IV 01/24/85 FRAZAR, Richard Ansel I 11/29/83 II 11/30/83 III 12/01/83 IV 02/07/84 V 02/08/84 VI 02/09/84 FULGNUM, Raymond Earl I 02/21/84 II 02/22/84 III 06/26/84 IV .06/27/84 V 06/28/84 VI 06/29/84 GAMON, Thomas H. I 03/13/84 II 03/14/84

ATTACHMENT 1 Proctdure No. LRP-2 Revision 2 Page 8 of 49 Date Issued: FEB 18198 DEPONENT'S NAME VOLUME DEPO DATE l

GEURTS, James R. I 04/04/84 II 07/16/84 GODSEY, Thomas Andrew l' I 12/12/84 GOLDBERG, Jerome H. I 07/28/83 II 11/28/83 GRANGER, Arnold J. I 01/05/84 II 01/06/84 l I 07/17/84 II 07/18/84 III 07/19/84 ,

GRAY, James David I 01/11/85 II 02/13/85 GREENE, William Telford I I 08/20/84 j II 08/21/84 i III 11/26/84 IV 11/27/84 Y 02/06/85 VI 02/07/85 GRIFFIN, Glenn Homer l I 01/14/85 II 01/15/85 III 01/16/85 IV 01/18/85 GRIMES, James I 02/06/84 II 02/07/84 III 02/08/84 IV 02/09/84 V 03/06/84 VI 03/07/84 VII 03/08/84 VIII 03/09/84 GRIMES, James Wendel/6005 I 09/24/84 GRIMES, James Wendel/4015 I 09/24/84

.i

- - - - . . - . . . . _ . . _ . . - . _ . , _ _ _ . , , - , , , _ _ . , , ...,,~,..y...,_,.,.__,--___.,,..,...,_..,_.7_.,, _ . . . . . . , , .

l ATTACHMENT 1 ' l Procedure No. LRP-2 I Revision 2 1 Page 9 of 49 Date Issued: FEB 18 Icc3 DEPONENT'S NAME VOLUME, DEPO DATE GRIMES, James Wendel/4004, 4018,4122,4140,6007, 6032,6042 I 08/22/84 GROTE, Stephen Henry I 11/30/83am II 11/30/83pm III 09/10/84 IV 09/11/84 V 09/12/84 VI 09/13/84 4

HANEIKO, John Bernard I 07/31/84 II 08/01/84 III 08/17/84 HANKS, Robert C. I 04/23/84  ;

II 04/24/84 1 III 05/16/84  !

IV 05/17/84 l V 05/18/84 I 04/15/85 i II 04/16/85 I III 04/17/85 HANKS, Robert C./4011 I 10/08/84 HANKS, Robert C./6024 I 10/08/84 )

MANSON, John W. I 01/16/85 II 01/17/85 III 01/18/85 HARDT, Michael Thomas I 02/08/84 II 02/09/84 III 08/27/84 IV 08/28/84 V 08/29/84 VI 08/30/84 VII 08/31/84 l VIII 10/01/84 l IX 10/02/84 l X 10/03/84 I HARRISON, Alben Wayne I 11/07/84 II 11/08/84 l l

l

. . _ _ - - . . - . - -. . . . - - . - . . .-.-.-.J

l ATTACHMENT 1 Procedure No. LRP-2 Revision Z Page 10 of 49 7-l Date Issued: FEB 18 U2 DEPONENT'S NAME VOLUME DEPO DATE HARRISON, Alben Wayne (Cont'd) III 11/09/84 IV 11/28/84 V 11/29/84 VI 11/30/84 HAWKS, James L. I 10/18/83 II 10/19/83 III 10/20/83 IV 02/13/84 HERNANDEZ, Ralph R. I 06/19/84 II 06/20/84 III 07/24/84 IV 07/25/84 V 07/26/84 VI 07/27/84 HILLAKER, John B. I 06/18/84 II 06/19/84 III 06/20/84 )

IV 06/21/84 HOE, Robert J. I 06/14/84 II 06/15/84 III 08/17/84 VI 08/18/84 V 08/19/84 VI 03/12/85 VII 03/13/85 VIII 03/14/85 IX 03/15/85 HORRIGAN, Larwence B., Jr. I 01/31/85 HOWELL, Gregory Alvin I 01/31/84am i II 01/31/84pm i JACKSON, John P. I 01/10/84  !

II 01/11/84 III 01/12/84 IV 04/23/85 V 04/24/85 VI 04/25/85

_-_ _ _____..____ . . _ _ _ _ _ _ ~ , _ _ . _ . _ . _ . . _ . _ _ _ _

ATTACHMENT 1 j Procedure No. LRP-2 Revision 2 Page 11 of 49 Date Issued: F E B I I' "' "- ' t 1

DEPONENT'S NAME VOLUME DEPO DATE )

JAUNAL, Garry W. I 07/24/84 I 10/16/84 l II 11/02/84 l l

JONES, Cecir Roy I 04/04/84 II 04/05/84 III 04/06/84 )

IV 05/09/84 V 05/10/84 VI 05/31/84 VII 06/01/84 VIII 06/04/84 IX ~06/05/84 X 06/07/84 XI 06/08/84 JONES, Ralph I 03/10/85 l

JORDAN, Peter Stanley I 11/01/83 II 11/02/83 III 11/03/83 IV 11/04/83  ;

V 11/21/83 1 VI 11/22/83 VII 11/23/83 VIII 12/06/83 IX 12/07/83 X 12/08/83 XI 05/22/84 XII 05/23/84 I 01/31/85 II 02/01/85 JORDAN, Thomas J. I 03/04/85 II 03/05/85 III 03/06/85 IV 03/07/85 V 03/08/85 JORDAN /BLAKLEY I 09/18/84 09/19/84 II III 09/20/84 IV 09/21/84 JORDAN / LEE I 08/07/84 II 08/08/84 j

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 12 of 49EB IC 1cy Date Issued:

DEPONENT'S NAME VOLUME DEPO DATE JORDAN / LEE (Cont'd) III 08/09/84

, IV 08/10/84 JORDAN /SALTARELLI I 05/08/84 II 05/09/84 KEFAUVER, Robert Chapman I 12/11/84 KEY, Henry Louis I 02/14/84 II 02/15/84 III 02/16/84 IV 02/17/84 V 03/06/84 VI 03/07/84 VII 03/08/84 VIII 04/11/84 IX 04/12/84 X 04/13/84 XI 05/30/84 XII 05/31/84 XIII 06/01/84 XIV 07/31/84 XV 08/01/84 XVI 08/02/84 XVII 10/31/84 KNAPP, Frederick E. I 05/08/84 II 05/09/84 III 05/10/84 IV 08/09/84 l V 08/10/84 KOHLER, Larry Ray I 06/18/84 (KONLER/WAWR2ENIAK) II 06/19/84 III 06/20/84 KOPAL, David J. I 07/18/84 LANDRY, Kenneth James I 09/04/84 II 09/05/84 III 09/06/84 IV 09/07/84 LEASBURG, Ronald I 06/06/84 II 07/02/84 III 07/03/84

l ATTACHMENT l' Procedure No. LRP-2 Revision 2 Page 13 of 49c O Date Issued: '

• ISU DEPONENT'S NAME VOLUME DEPO DATE LEBLANC, Julie I 07/12/84

' LENT 2, James L. I 11/06/84 II 11/07/84 III 12/27/84 LESCHBER, Ervin I 03/19/84 II 03/20/84 III 03/21/84 IV 03/22/84 V 03/23/84 LEWIS, Edward Lamore III I 07/24/84  !

II 07/25/84 i III 07/26/84 LOGAN, Timothy Keith I . 01/24/84 II 07/11/84 l III 07/12/84 I IV 03/26/85 V 03/27/85 LONG, David Glynn I 08/08/84 II 08/09/84 l I 08/16/84 I 12/12/84 II 12/13/84 III 12/14/84 l l

LUDWIG, Mark I 03/27/85 II 03/28/85 l l

LUKE, Marion T. I 10/10/83 II 10/11/83 III 10/12/83 IV 10/31/83 V

11/01/83 l VI 11/02/83 VII 11/03/83 VIII 11/04/83 IX 12/01/83 X 12/02/83 .

XI 12/15/83 l XII 01/09/84 j XIII 01/10/84 XIV 01/11/84

, - . - - . .. , ~ _ . . - . -- - .- . , , . - _ _ . . - . . - . -

l l

ATTACHMENT 1 Procedure No. LRP-2 i Revision 2 Page 14 of 49 Date Issued: FEB 10 r ;

DEPONENT'S NAME VOLUME DEPO DATE LUKE, Marion T. (Cont'd) XV 01/12/84 XVI 01/30/84

. XVII 01/31/84 XVIII 02/01/84 XIX 02/02/84 XX 02/03/84 XXI 08/21/84 XXII 08/22/84 XXIII 08/23/84 LUKE, Marion T. (To be incorporated 1500a 01/10/84 -

into Volume XIII of Luke, Marion T. 01/10/84) Re>I. )

McCLURE, C. Alan I 09/06/84am II 09/06/84pm l III 09/07/84 l I 09/04/84 II 09/05/84 III 01/17/85 IV 01/18/85 ,

l McDANIEL, Richard M. I 02/28/84 II 02/29/84 ,

1 McPHERSON, Carl I 06/05/84 -

MANASCO, Glenn D. I 12/04/84 MARSHALL, Glenn Allen I 03/06/84 II 03/07/84 III 03/08/84 MENGER, William M. I 09/11/84 I II 09/12/84 III 09/13/84 IV 09/14/84 V 05/07/85 VI 05/09/85 VII 05/10/85 l MESSER, Clarence R. I 11/14-15/84 MEYER, Marc Jan I 08/02/83am II 08/02/83pm

t ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 15 of 49 Date Issued: FEB 1019:3 VOLUME DEPO DATE DEPONENT'S NAME i MEYER, Marc Jan (Cont'd) III 08/03/83 -

IV 08/04/83am V 08/04/83pm

- VI ,

08/05/83 VI 09/19/83 IAw.2 '

VII 09/20/83 VIII 09/21/83 l IX 09/22/83am X 09/22/83pm XI 09/23/83 i XII 10/24/83 ,

XIII 10/25/83 I XIV 10/26/83am l XV 10/26/83pm XVI 10/27/83 i XVII 10/28/83 .

XVIII 11/14/83 l XIX 11/15/83 l XX 11/16/83 l J

MEYER/ LEE I 03/27/85 ,

03/28/85 II III 03/29/85 i MILLAS, George S. I 02/14/85 l i

l MITCHELL, Billy I 06/14/84 l II 06/15/84 MONROE, James R. I 08/29/83 II 08/30/83 III 10/24/83 IV 10/25/83 '

V 10/28/83 l 1

l MOONEY, John T. I 04/16/84 i II 04/17/84 '

III 04/18/84 IV 04/19/84 MOORI, Joseph Ward I 01/17/84 MORROW, Irwin P. I 03/11/95 i .

09/25/84 MORGAN, Wade H. I II 09/26/84 ,

-_ - _ . _ - _ . _ _ _ _ _ _ _ _ - - _ _ ___ . . _ . ~ _ - _ - _ . - _ _ . _ . . - _ _ . . . _ _ - _ . . _ - . _ _ _ _ _

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 16 of 49FEB 18199,3 Date Issued DEPONENT'S NAME VOLUME DEPO DATE MORGAN, Wade H. (Cont'd) III 09/27/84 IV 09/28/84 V 03/26/85~

VI 03/27/85 VII 03/28/85 MORRIS, George Laigle I 05/07/84 II 05/08/84 III 05/09/84 IV 05/10/84 V 05/21/84 VI 05/22/84 VII 06/13/84 VIII 06/14/84 IX 08/02/84 MOSER, James Stuart I 03/26/84 II 03/27/84 III 03/28/84 IV 03/29/84 V 03/30/84 MUELLNER, Frank E. I 11/28/83 II 12/12-13/83 III 12/14/83 IV 12/15/83 i V 12/29/83 '

MUNISTERI, Joseph George I 04/02/84 II 04/03/84 III 04/04/84 IV 04/09/84 V 04/10/84 VI 04/11/84 VII 04/12/84 MUSCENTE, Matthew D. I 05/24/84 II 05/25/84 FATARAJAN, T. J. I 01/30/85 NEWTON, Dennis E., Jr. I 08/03/84 II 08/06/84 III 08/07/84 i

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 17 of 49.

Date Issued: REB 181;p3 DEPONENT'S NAME VOLUME DEPO DATE NICHOLS, Norman I 10/11/84 O'BRIEN, Francis David

• I 09/05/84 II 01/15/85 OLVER, David J. I 11/28-29/83 II 11/30/83 III 12/01/83 IV 12/02/83 V 12/08/83 VI 12/09/83 VII 01/16/84 )

VIII 01/17/84 XI 01/19/84 X 01/20/84 OPREA, George W., Jr. I 07/27/83 II 08/29/83 III 12/05/83 IV 06/04/84 V 06/05/84 VI 06/06/84 VII 06/07/84 I VIII 06/08/84 IX 06/11/84 X 06/12/84 XI 06/18/84 XII 06/19/84 XIII 06/25/84 XIV 06/26/84 XV 06/27/84 ,

XVI 06/28/84 1 XVII 06/29/84 l XVIII 07/20/84 '

XIX 07/24/84 XX 08/28/84  !

XXI 08/29/84 )

i OVERSTREET, Harry G. I 04/10/84 II 04/11/84 III 04/12/84 PAVLICEK, Joseph Henry I 12/19/84 II 12/20/84 III 01/03/85

~

~

- ' ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 18 of 49 Date Issued: FEB 10 t1 DEPONENT'S NAME VOLUME DEPO DATE PETTERSSON, C. Bernt I 10/23/84am ,

10/23/84pm I l II 10/24/84

. III 10/25/84

~

PETTY, Robert I 02/02/84

' II 02/03/84  !

III 03/08/84 I l

PEVERLEY, Richard W. UNNUMBERED 06/16/83am  !

UNNUMBERED 06/16/83pm II 03/28/84 III 03/29/84' I 08/14/84 II -

08/15/84 III 08/16/84 IV 08/17/84 V 11/13/84 VI 11/14/84 VII 04/09/85 PHELPS, Jeffrey sellers I 08/14/84 II 08/15/84 PULLIN, A. Daryl I 02/14/84 II 02/15/84 ,

III 02/16/84 IV 02/17/84 RASNICK, Sid A. I 04/29/85 II 04/30/85 i III 05/01/85 REDER, Ronald E. I 08/06/84 4

II 08/07/84 ,

III 08/08/84 IV 08/09/84 i V 08/10/84 REJCEK, Milton F. I 08/24/84 '

I 08/30/84 RICE, William Mitchell I 05/29/84 I II 05/30/84 l

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 l Page 19 of 49 <

Date Issued: FEB IC 1;;- I DEPONENT'S NAME VOLUME DEPO DATE l l

RICE, William Mitchell (Cont'd) III 05/31/84 4

IV 06/01/84 RICHARDSON,. Ernest B., Jr. I 11/01/83 II 11/02/83 j III 11/11/83  :

I 10/11/84 RIDDLE, Edward Maurice I 07/G8/83 ROBERTS, John Paul I 08/16/84 RODGERS, Shawn I 08/16/84 II 08/17/84 ROGAN, Steven L. I 07/11/84 I l

I ROMEO, Robert A. I 05/29/84 II 05/30/84 III 05/31/84 IV 06/01/84 ,

V 08/29/84 '

l ROSE, Gerald R. I 06/26/84 II 06/27/84 l III 06/28/84 1 IV 06/29/84 l

RUSSELL, Ronald R. I 04/18/84 I II 04/19/84 l III 04/20/84 IV 04/27/84 RUSSELL /ENGEN I 04/30/84 II 05/01/84 III 05/02/84 IV 05/03/84 SALTARELLI, Eugene A. I 10/25/83 I 07/16/84 II 07/17/84 III 07/18/84 IV 07/19/84 l l

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 20 of 4g.EB Date Issued: r 181996 DEPONENT'S NM1E VOLUME DEPO DATE SALTARELLI, Eugene A. (Cont'd) V 07/20/84 1

' I 12/11/84 {

II 12/12/84 l 12/13/84 III l IV 12/14/84 V 01/09/85 1 VI 01/10/85 l l

SCHAEFFER, Stephen 03/25/85 I l II 03/26/85 i

SCHOENEBERG, Allan I 09/12/83 II 09/13/83 I 11/15/84 II/4006 11/30/84 i I 11/16/84 l II/4017 .

11/30/84 1 l

1 SIANO, Michael I 01/30/85 SIGNORELLI, Joseph Anthony I 01/27/84 SMITH, Ronald C. I 10/31/84 II 11/01/84 SPIRES, George V. I 09/11/84 STEINMANN, Garland I 01/10/85 STINSON, Ronald C. I 07/17/84 II 07/18/84 III 07/19/84 IV 07/20/84 V 04/16/85 VI 04/17/85 SUMPTER, James R. I 02/07/84 TOBIAS, Richard A. I 03/06/84 II 03/07/84 III 03/08/84 IV 03/09/84

l ATTACHMENT l' Procedure No. LRP-2 I Revision 2 .

Page 21 of 49 (

Date Issued: FEB 10 1933 l DEPONENT'S NAME VOLUME DEPO DATE 1 1

TRAYLOR, Robert C. I 02/08/84 II 02/09/84

- III 02/10/84 .

IV 01/08/85 l V 01/09/85

' VI 01/10/85 H

' VII 01/11/85 TURNER, Carl M. I 11/01/84 TURNER, Edward Allen UNNUMBERED 07/12/83 II 04/25/84 III 04/26/84 ULREY, Robert I 04/24/84 II 04/25/84 III 04/26/84 IV 08/22/84 i V 08/23/84 UNDERWOOD, Thomas Edward I 12/11/84 VALENTINE, Jack V., III I 03/15/84 I 08/14/84 II 08/15/84 III 08/16/84 I 12/20/84 II 12/21/84 l

> VESELKA, Steve I 12/12/83 ,

t II 12/13/83 l III 12/19/83 IV 12/20/83 V 12/21/83 I 10/18/84 I 02/04/85 II 02/05/85 1 III 02/06/85

, VIACLOVSKY, Sylvester I 05/15/84 II 05/16/84 III 06/28/84 IV 06/29/84 I

I ATTACH $ENT 1 Procedure No. LRP-2 I Revision.2 1 Page 22 of 49 '

Date Issued:FE B 10 h, , ,,p DEPONENT'S NAME VOLUME DEPO DATE VURPILLAT, Ray J.

I 05/01/84 II 05/02/84 III 06/12/84 IV . 06/13/84 I WAHL, James C.

4

-I 01/09/85 WALKER, Philip I 06/21/84 II 06/22/84 WAWRZENIAK, John H. I 06/05/84 II 06/06/84 III 06/07/84 IV -

06/08/84 WAWRZENIAK (KOHLER/WAWRZENIAK) IV 06/21/84 I V 06/22/84 I WAWRIENIAK/ JORDAN I 04/03/84 1 II 04/04/84 )

7II 04/05/84 '

IV 04/06/84 WEATHERS, Walker S. I 08/21/84 II 08/22/84 III 08/23/84 IV 08/24/84 V 10/24/84 VI ,

10/25/84 I 10/23/84 WEBB, John K.

I 08/23/83 II 08/24/83 III 03/08/84 1 IV 03/09/84 I 02/19/85 l II 02/20/85 III l 02/26/85 l IV 02/27/85 V 03/21/85 VI  !

04/03/85  :

VII 1 04/04/85 WEBB, John K./4008 '

I.

,09/26/84 i

ATTACHMENT 1  !

Procedure No. LRP-2 Revision 2 Page 23 of 49 Date Issued: FEB 181996  ;

I DEPONENT'S NAME VOLUME DEPO DATE i WEBB, John K./4013 I 10/09/84 l

WEBB, John K,/4022 I 10/09/84 WEINTRAUB, Myron I 01/05/84 II 01/06/84 III 02/02/84 WILKERSON, Benjamin P. I 02/05/85 II 02/26/85 i

WILLIAMS, Edward Richardson I 04/16/84 WILLIAMS, Trenton Donald I 06/05/84 WILSON, Logan D. I 02/05/85 II 02/06/85 III 02/07/85 i IV 02/08/85 '

V 03/05/85 VI 03/06/85 VII 03/07/85 WORMINGTON, William L. I 04/30/85 II 05/01/85 l III 05/02/85 IV 05/06/85 DEPOS1 TION LOG CLOSED - OUT EFFECTIVE 06/10/85

--,%, , ,__.. -.- - - , - ,_,,,, ,,,--,,-.,,.-,,-.,,---,,,__,,,--.,m.- ,, --

- _ , - , , - - -_ym

k l l

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 24 of 49 Date Issued: '-EB 1819?G HL&P v. B&R Litigation Record -

Material _to be Reviewed

-IA: BECHTEL RESPONSES ' ,

Section IA consists of Bechtel responns-to the questions propounded by defendant Brown & Root in its Notice of Deposition on Written Questions served on January 28, 1984.

The , wr.i tt en Bechtel responses were filed during the period 07/27/84 through 11/21/84. For ease of reference SLI will, in its own documen-tation, refer to one date only (07/27/84) when the transmittals were initiated.

~

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e I e 4

-s e 4[

.c-r

-r en,- .

• 4

ATTAC' H MENT 1 Procedure No. LRP-2 Revision 2 Page 25 of 4 DateIssued:pbbICI#~' ...

HL&P vs B&R LITIGATION REVIEW Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EA-002 Reactor Containment Bldg.(Units 1&2)

Diesel Generator Bldg.(Units 1&2)

EA-003 Fuel Handling Bldg. (Units 1&2) General Specs. & Architectural Design EA-004 Gate House Complex EA-005 Auxiliary Bldgs. (Units 1 & 2)

EA-006 Miscellaneous Yard Structures EA-007 Turbine Generator Bldg.

EA-008 Fireproofing All Bldg.

EA-010 Level I Shop coatings EA-011 Level I Field Coatings EA-012 Level II/III Shop coatings EA-013 Level II/III Field Coatings EA-014 Plant Security System EC-100/101 SSI Seismic Analysis Category I Structures EC-102 Standard Specifications EC-103 General Structural Design Criteria EC-104 Standard Calculation and Drawings EC-105 Misc. Design Documents and Calculations EC-110-113 Review of Bechtel Summary Work Packages RCB Shell I,RCBII,RCBIII,RCBIV Updated: 10/28/85

l ATTACH 4ENT 1 Procedure No. LRP-2 Revision 2 Page 26 of 49 3 HL&P vs B&R LITIGATION REVIEW Date Issued: pg g M >

Material to be Tsviewed IA. Bechtel Responses Bechtel Number Subject EC-120-121 -------------------- -------------------

RCB Internal I, Shield Walls RCB Internal II, NSSS Miscellaneous EC-122 RCB Internal III, Steel Reverificction EC-130-132 Mechanical & Electrical Auxiliary Blgd.

I, MEAB II, MEAB III EC-135 Isolation Valve Cubicle EC-138 Diesel Generator Building EC-140 Fuel Handling Bldg.

EC-142/EM-510 Essential Cooling Water, Intake &

Discharge system EC-145 Turbine Generator Building EC-150 circulating Water Intake & Discharge Structures.

EC-151 Civil Site and Yard 1

EC-155 I Class 1E Underground Raceways  !

EC-157 Misc. Yard Structures & Bldg. I EC-160 Geotechnical Settlement Studies EC-161 Essential Cooling Pond EC-163 Geotechnical Design Documents EC-165 Condensate Storage Tank EC-170 Cooling Reservoir  !

EC-171 Spillway Facility I l

Updated: 10/28/85 l

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 27 of 49 HL&P vs B&R LITIGATION REVIEW Date Issued:FEB 18 to:-  ;

Material to be Reviewed '

IA. Bechtel Responses 1

l Bechtel Number Subject EC-172 ----------- ...-------------------------

Blowdown Facility l EC-173 Reservoir Makeup Pumping Facilities I EC-174 Heavy Civil -- Railroad EC-175 Site Drainage EC-176 Flood Design EC-177 Thermal Analysis EC-181 Pipe Whip restraints Inside Containment EC-186 HVAC Ducts & Duct Supports EC-195 Heavy Rigging EE-200 Main Generation System EE-201 Non Class 1E 13-8 KV AC Power Distribution System EE-202 4.16 KV Auxiliary Power Distribution l System ( Non Class 1E) I EE-203 480 V. Auxiliary Power Generation & l Distribution System EE-205 ESF 480 V. Auxiliary Power Distribution System EE-206 Non Class 1E 250 VAC Power Distribution System EE-207 Non Class 1E 125V AC Power EE-208 Non Class 1E 48 VAC power Distribution Updated: 10/28/85

\

ATTACHMENT 1 l Procedure No. LRP-2  :

Revision 2 Page 28 of 49 ,

HL&P vs B&R LITIGATION REVIEW Date Issued: FEB 181998 l Material to be Reviewed l

\

IA. Bechtel Responses Bechtel Number Subject EE-209 Class 1E 125 VAC Power Distribution System.

EE-210 Class 1E 120 VAC Power Distribution System EE-211 Grounding System EE-212 Cathodic Protection System EE-213 Lighting System l EE-214 Communication System EE-215 Heating Tracing & Freeze Protection EE-216 Lighting Protection for Structures I I

EE-217 Circuit & Raceway Schedule EE-218/EJ-321 Miscellanious Components, Equipment & pgg,2, Systems and telemetry system EE-219 .

Physical Arrangements E21-E26 EE-219 Physical Arrangements E32-E36 EE-219 Physical Arrangements E41A & E43-C EE-219 Physical Arrangements E43 EE-239 Physical Arrangements E44 & E45 EE-219 Physical Arrangements E46 EE-219 Physical Arrangements E51 EE-219 Physical Arrangements ES2 EE-219 Physical Arrangements E53 & E54 Updated: 10/28/85

ATTACHMENT'l  !

Procedure No. LRP-2 Revision 2 l Page 29 of 49 Date Issued: REB 1819:..3 HL&P vs B&R LITIGATION REVIEW Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EE-219 Physical Arrangements E61-E66 EE-219 Physical Arrangementis E71 EE-219 Physical Arrangements E72 EE-219 Physical Arrangements E73 EE-219 Physical Arrangements E74 EE-220 Separation Criteria EE-222 Cables & Calculations i j

EE-223 Electrical Cable Tray Supports l EE-224 Non Class 1E 120 V Vital AC System EJ-300 Plant Computer EJ-301 Electrical Work Subpackage Control Boards EJ-303 i ESF Actuation System and ESF Load Sequence l EJ-306 Radiation Monitoring System EJ-310 ,

Inoperable Status Monitoring /ESF l Monitoring EJ-313 Core Instrumentation EJ-314 Reactor Protection System EJ-315 Process Sampling System EJ-316 Loose Parts Monitoring System EJ-318 Seismic Monitoring System Updated: 10/28/85

ATTACHMENT 1 Procedure No. l.RP.2 Revision 2 Page 30 of 49 HL&P vs B&R LITIGATION REVIEW Date Issued: FEB 1819:.~

Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject

---

---------------------------------------- r fJ. S EJ-351 Instrumentation Tubing, Tube Fittings, Shut-off Valves, Pipe and Pipe Fittings 1 EJ-352 Temperature Instrumentation & Local Instrument Cabinets EJ-353 Miscellaneous Instruments, Offline EJ-354 Miscellaneous Instruments - Sensors Modules & Monitors EJ-355 Miscellaneous Instruments - Non Process ,

TYPE l i

EJ-356 Miscellaneous Instrumentation Line Or l Equipment EJ-358 Instrument Pressure Switches EJ-360 Pressure Gauges EJ-361 Instrument Level Switches EJ-362 Instrument Pneumatic Controllers EJ-364 Instrument Level Gauges EJ-365 Instrumentation Electronic Transmitter EJ-36C Differenti'al Pressue Guages EJ-367 Control Valves EJ-368 Safety Relief Valves EJ-369 Primary Flow Elements Updated: 10/28/85

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 31 of 49 HL&P vs B&R LITIGATION REVIEW Date Issued: FEB ] E is.

Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EJ-370 -_ ---------__-----------------_---_----

Miscellaneous Analog Control Systems

{

EJ-371 I Instrument Location Drawings EJ-372 Instrument Installation Details EJ-373 Instrument Isometric Drawings EM-400 Reactor Coolant System EM-401 Chemical & Volume Control System EM-402 Safety Injection System EM-403 Component Cooling Water System EM-404 Spent Fuel Pool Cool'ing & Cleanup System EM-405 Containment Spray System EM-406A Underground Piping EM-406B Essential Cooling System /ECP Makeup &

Blowdown EM-407 Reactor Head Degassing EM-408 Auxiliary Feedwater System EM-409 Steam Generator Blowdown EM-410 Standby Diesel Generators EM-411 Miscellaneous ASME III, Class 3 Pumps EM-412 Field Erected Stainless Steel Tanks EM-413 Resin Fill Tanks EM-450 Main & Extraction Steam Updated: 10/28/85 l

ATTACHMENT 1 '

Procedure No. LRP-2 Revision 2 Page 32 of 49 HL&P vs B&R LITIGATION REVIEW Date Issued: FE8 10 1;:

Material to be Reviewed IA. Bechtel Responses '

Gechtel Number Subject i EM-451/EM-452  !

Condensate System, Automatic Controls in the condensate System EM-453 Heater Drips & Drain System EM-454 circulating Water System 1 EM-455 Condensor Air Removal System l

EM-456 Lube Oil System EM-457  !

Turbine Generator & Auxiliaries EM-459 Deaerator ,

EM-500 Water Supply System EM-501 Fire Protection System EM-502 Make-up Domineratizer System EM-503 Auxiliary Steam System EM-504' Fuel Oil Storage & Transfer System l Au. 2 EM-505 Non Radioactive Gas Systems EM-507 Auxiliary Cooling Water System EM-508 Instrument, Service, & Breathing Air Systems EM-509 Potable Water Systems EM-510 Station Cranes & Plant's Monorails EM-511 Insulation EM-512  !

Sodium Hypochlorination System t

Updated: 10/28/85

- . . - - . . . - . , - ~ , .

ATTAC'HMENT 1 Procedure No. LRP-2 Revision 2 Page 33 of 49FEB 10 ' - >

HL&P vs B&R LITIGATION REVIEW Date Issued:

Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EM-513 Acid & Caustic System EM-515 Non-Radioactive Chemical Waste System EM-517 Temporary Strainers EM-518 Shop Fabricated Atmospheric Tanks &

Pressure Valves EM-519 General Service Horizontal Pumps EM-520 Horizontal Pumps EM-522 Oily Waste Treatment Facilities EM-523 General Service Vertical Pumps &

Strainers EM-524 General Service Pressure Vessels EM-525 Sump Pumps EJ-317 Vibration Monitoring System EM-526 General Servic'e Steam Traps EM-527 Field Errected Tanks EM-550 Station HVAC EM-551 EAB & Control Room HVAC EM-552 Mechanical Auxiliary BLDG. HVAC System EM-553 Fuel Handling Bldg. HVAC System EM-554 Diesel Generator Bldg.

EM-555 Reactor Containment Bldg. HVAC System Updated: 10/28/85

ATTACNMENT1 Procedure No. LRP-2 Revision 2 Page 34 of 49 HL&P vs B&R LITIGATION REVIEW Date Issued: FEB 181999 Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EM-556 ----------------------------------------

Turbine Generator Bldg. HVAC System EM-557 Miscellaneous Bldgs. HVAC System EM-558 Main SystemSteam Isolation Valve Cubicles HVAC EM-559 Safety Class Refrigeration Units EM-560 Nonsafety Class Refrigeration Units EM-561 Nonsafety Class Heat Exchangers EM-562 Safety Class Refrigeration Units EM-563 Safety Class Fans EM-564 Nonsafety Class Fans EM-565

, Nonsafety Class Filters EM-566 Safety Class Filters EM-567 Nonsafety Class Fans EM-568 Nonsafety Class Exhaust Fans EM-569 Nonsafety Class Air Handling Units EM-570 Safety Class /Nonsafety Class Dampers EM-571 Safety Class /Nonsafety Class Ductwork EM-572 Chilled Water Systems EN-600 Licensing Document Review EN-601 System Interaction 5 Integration EN-602 Pressure / Temperature Transient Analysis Updated: 10/28/85

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 35 of 49 HL&P vs B&R LITIGATION REVIEW Cate Issued: FEB 18 mg Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EN-603 ___________________..__________________.

ALARA & Shielding Criteria EN-604 Equipment Qualification EN-605 Safe Shutdown Criteria EN-606 Protection Against Natural Phenomena &

External Hazards EN-612 Boron Recycle System EN-613 Radioactive Vent & Drain System EN-614 Liquid Waste Processing System EN-615 Solid Waste Processing System EN-616 Gaseous Waste Processing System EN-618 Hydrogen Control System EN-619 Review Of The Quadrex Report EN-630 Vendor Control Program EP-700 Plumbing EP-701 Safety Related Welding EP-702/703 Mechanical Auxiliary Bldg.

EP-704 Piping - FHB EP-705 Diesel Generator Bldg.

EP-706 Piping RCB EP-707 Turbine Generator Bldg.

EP-708 Miscellaneous Bldg. (Yard)

Updated: 10/28/85

, - - - --,-,-, ,--,,-~.- , ,---,------,-.------e----yn ,-e---v r,., . --- , - ~ ~ - . e ,-- n w,- -

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 .

Page 36 of 49 HL&P vs B&R LITIGATION REVIEW Date Issued: FEB 18 n -

Material to be Reviewed IA. Bechtel Responses Bechtel Number Subject EP-709 --- ...----------- ---------------------

Model Shop EP-714 Preservice & Inservice Inspection EE-204 4.16 KV Auxiliary Power Generation &

Distribution System EC-162 Geotechnical Field Data

, EM-514 Integrated Leak Rate Test Updated: 10/28/85

-I l

l 1

-l

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 37 of 49 Date Issued: FEB 18199g HL&P v. B&R Litigation Record Material to be Reviewed II: EXPERT REPORTS VOLUME RER0RT REPORT SUBJECT NUMBER _ DATE S. Levy Inc. Report on B&R Engineering on STP 1 10/01/84 2 10/01/84 J. R. Wells Concrete Work at STP 1 09/26/84 CYGNA Energy QA Programmatic and Procedural Service Study 1' 04/30/84 2A 04/30/84 28 04/30/84 2C 04/30/84 CYGNA Energy QA Program Implenentation Study Service 1 12/17/84

, J. C. Lavalle NSSS Supplier and A/E Interface 1 10/01/84 r - , .---- - - -, - - - , . - - ,

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 38 of 49 Date Issued: FEB 181999 HL&P v. 8&R Litigation Record Material to be Reviewed I!!: INTERROGATORY ANSWERS Section III is a listing of Interrogatories and Requests for Admissions to be Reviewed. The listing identifies specific Questions / Answers to be reviewed.

No responses were ever filed to a number of interrogatories; con-sequently, there is no material to review. Such interrogatories are marked with an asterisk (*) in the listing to follow.

t G

J

-- - - - - - - - - - . .--n... - - -----, - - - -.e. --,, .--n.- .-.n-. ,

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 39 'of 49 Date Issued: FEB 181933 III. INTERROGATORY ANSWERS Date Filed Questions to be Reviewed Items 03/31/82 6.13,14,20,21,24,25, Brown & Root's First Set of Interrogatories ,

26,28,29,30,31,33,34,36, to Houston Lighting & Power Company l 37 04/12/82 6,13,14,20,24,25,26 Brown & Root's First Set of Interrogatories i to Central Power & Light Co. I l

04/15/82 6.13,14,23,24,25,26, Brown & Root's First Set of Interrogatories i 29,30,31,32 to the City of San Antonio l

04/16/82 6.13,14,19,21,22,23,24 Brown & Root's First Set of Interrogatories l 25,26,27,28,29 to the City of Austin 05/17/82 1,3,5,6,7,10,13 Ha111 burton's First Set of Interrogatories to Houston Lighting & Power Co.

05/17/82 1,3,4,5,8,10,11,13 Ha111 burton's First Set of Interrogatories  !

to the City of Austin '

l 05/17/82 1,3,4,7,10 Ha111 burton's First Set of Interrogatories i to the City of San Antonio l

05/17/82 1,3,6,7,13 Ha111 burton's First Set of Interrogatories to Central Power & Light Co.

08/02/82 14 Central Power & Light Co.'s First Set of Interrogatories to Halliburton 09/03/82 4,7,8,11,12.13,14,15 , Houston Lighting & Power Company's First 16,17,18,19,22.24,27 Set of Interrogatories to B&R 1 09/22/82 19,21,22 City of Austin's First Interrogatories to Halliburton Company 1 12/10/82 39,42,44,46 Brown & Root's Second" Set of Interrogatories to Houston Lighting & Power Co.

12/10/82 10,11,23,28,29,33,39,41 The City of San Antonio's First Interrogatories to Halliburton Co.

01/24/83 35,37,38,40 Brown & Root's Second Set of Interrogatories to the City of Austin l

l 1

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 40 of 49 Date Issued: FEB 1819?G Date Filed Questions to be Reviewed Items 02/16/83 1-19,21,23,24,25,31 Houston Lighting & Power Company's Second Set of Interrogatories to Brown & Root 02/16/83 9, 10 Plaintiff's Request for Admissions Pursuant to Rule 169 03/16/83 48,53,54,55 Brown & Root's Third Set of Interrogatories to Houston Lighting & Power Company

• 03/18/83 2-6,10,13,17-21,26,27, Plaintiffs' Third Request for Admissions 31,33-35,38-40,43(p.22), Pursuant to Rule 169 51

• 03/22/83 Review All Answers Plaintiff's Second Request for Admissions Pursuant to Rule 169 04/27/83 58-62,65,57 B&R's Fourth Set of Interrogatories to HL&P Co.

05/23/83 Review All Answers HL&P Co.'s Amended Second Set of Interrogatories to Brown & Root 07/25/83 3,4,5,6 Houston Lighting & Power Co.'s Third Set of Interrogatories to B&R 10/03/83 Review All Answers HL&P Co.'s Fourth Set of Questiens to 1 Halliburton Corp. & B&R, Inc.

10/05/83 Review All Answers Plaintiffs' Fifth Request for Admissions Pursuant to Rule 169 l 10/05/83 Review All Answers Plaintiffs' Sixth Request for Admissions-Pursuant to Rule 169 10/26/83 3-12,15-27 City of Austin's First Request for Admissions 10/31/83 Review All Answers HL&P Co.'s Sixth Set of Interrogatories to Brown & Root -

10/31/83 Review All Answers Brown & Root's Sixth Set of Interrogatories to Houston Lighting & Power Company 11/04/83 1-3,6,8,10-13,14(12) City of Austin's Second Request for Admissions 11/14/83 3-6,10,13.16-21,25-27, San Antonio's First Request for Admissions 30,31,34-38,41,43,46 Pursuant to Rule 169 49-57,67,76,78.79,82 I

I I

l ATTACHMENT i Procedure No. LRP-2

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Revision 2 Page 41 of 49 Date Issued: FEB 18 1936 Date Filed Questions to be Reviewed Items

• 11/21/83 ReUiew All Answers First Request for Admissions to Brown &

Root 11/21/83 2-7,10-31 Second Request for Admissions to Brown &

Root 12/01/83 98,103,104.107,108.110 Brown & Root's Seventh Set of 112,114-118,120-122 Interrogatories to HL&P Co.

12/21/83 Review All Answers Third Request for Admissions and Interrogatories to Brown & Root 4

01/16/84 Review All Answers HL&P's Eleventh Set of Interrogatories to Brown & Root 01/18/84 28,50-54 Halliburton's Fourth Set of Interrogatories  !

to Houston Lighting & Power Company 01/18/84 28 Halliburton's Fourth Set of Interrogatories to the City of Austin 01/18/84 28,37,38 Halliburton's Fourth Set of Interrogatories to Central Power & Light Company 1

01/18/84 25 Halliburton's Fourth Set of Interrogatories to City of San Antonio i

02/01/84 Review All Answers Brown & Root's Ninth Set of Interrogatories to KL&P

• 02/01/84 Review All Answers Brown & Root's Fourth Set of 1

Interrcgatories to City of San Antonio 02/01/84 Review All Answers Brown & Root's Fourth Set of Interrogatories to CP&L 02/01/84 Review All Answers Brown & Root's Fifth Set of Interrogatories to City of Austin (2. Sets: 2/1/84; 2/14/84) 02/06/84 Review All Answers Houston Lighting & Power Company's Thirteenth Set of Interrogatories 02/06/84 56-58,60-63,82,83,91, Halliburton's Fifth Set of Interrogatories .

92  !

to the City of Austin 02/06/84 54-56,58-60,89,90 Halliburton's Fifth Set of Interrogatories to the City of San Antonio l l

l i

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 of 49

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Page 42 Date Issued: ' FEB 18 togg j Date Filed Questions to be Reviewed Items 02/06/84 59-41,63-65,85,86, Hal11 burton's Fifth Set of Interrogatories 94,95 to RL&P Co.

02/06/84 57-59,61-63,83,'4, 8 Ha111 burton's Fifth Set of Interrogatories 92,93 to CP&L Co.

I 02/17/84 1-4 City of Austin's Fourth Set of i

I Interrogatories to Brown & Root I 02/17/84 1-4 City of Austin's Fifth Set of l

l Interrogatories to Halliburton Co. l 02/22/84 1,2,4,7-10,13,14,21-23', Houston Lighting & Power Company's Eighth 26-28,32,35,38,39,44, Request for Admissions 46-50,54.55,57-60  !

l 02/22/84 1-3,9,11,13,16-18,23-25 Houston Lighting & Power Company's Ninth l

l 32,33,36 Request for Admissions l 02/22/84 1-16,19-23,26,28-32,40, Houston Lighting & Power Company's Tenth 1 l

41,44-50,52-54,56,61,63, Request for Admissions 65,66,68,69,72-88.91,93, 96,97,99,101,105 02/27/84 Review All Answers Brown & Root's Tenth Set of Interrogatories to HL&P Co.

03/02/84 1-5,7,8,11-17 City of Austin's Sixth Set of Interrogatories to Brown & Root. Inc.

03/05/84 63,66,67,85-88 City of San Antonio's Second Set of l

Interrogatories to Halliburton 04/16/84 2

, RL&P Co.'s Fourteenth Set of Interrogatories to Brown & Root, Inc.

04/16/84 189-196,198-207 Brown & Root's Twelfth Set of Interrogatories to HL&P Co.

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05/04/84 Review All Answers B&R's Thirteenth Set of Interrogatories to RL&P Co.

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ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 43 of 49 Date Issued: 'FEB 18 1996 Date Filed Questions to be Reviewed Items 05/11/84 1-12,15-19,21,22,25-29, Fourth Request for Admissions and 33-41,44-47,51-54,57 Interrogatories to Brown & Root 58,61,64,65,68,69,72-84, 87,88,91,92,95-102, 105-107,110-112.115-121, 126-129,132-138,141,142, 145-147,150-152,155, 158-163.166-169,172, 173,176,177,180,181,184, 185,188,191-193,196,197, 200-202.205-208,211,214, 215,218,221,224,227,230, 233-235,238,241-244, 247-249,252,255,256,259, 260,263,266-269,272.275, 278,281,284,287,290,293, 294,297,298,301,304,307, 310,313,316,319,320,323, 326,329,332,335,338,341, 344.347,350,353,356,359 05/15/84 Review All Answers City of Austin's Seventh Set of Interrogatories to Brown & Root, Inc.

05/21/64 1,2 City of Austin's Eighth Set of Interrogatories to Brown & Root 05/24/84 Review All Answers Brown & Root's Seventh Set of Interrogatories to City of Austin 05/24/84 Review All Answers Brown & Root's Fifth Set of Interrogatories to City of San Antonio 06/08/84 Review All Answers Brown & Root's Fifth Set of Interrogatories to Central Power & Light Company 06/08/84 Review All Answers Brown & Root's Fifth Set of Interrogatories to Central Power & Light Company (No Certi-ficate of Service). .

06/08/84 Review All Answers Brown & Root, Inc.'s 14th Set of Interrogatories to RL&P Co.

06/08/84 Review All Answers Brown & Root, Inc.'s 8th Set of Interrogatories to the City of Austin I 06/08/84 Review All Answers Brown & Root. Inc.'s 6th Set of Interrogatories to the City of San Antonio

ATTACHMENT 1 Procedure No. LRP-2 Revision.2 Page 44 of 49 Date Issued: FEB 18 1923 ,

Date Filed Ouestions to be Reviewed Items 06/14/84 Review All Answers Brown & Root's Fourteenth Set of Interrogatories to EL&P Co. '

• 06/18/84 1 Houston Lighting & Power Company's I Eighteenth Set of Interrogatories to Brown

& Root. Inc. '

06/21/84 Review All Answers HL&P's (19th) Interrogatory to Brown & Root &

Halliburton Inc.

07/02/84 Review All Answers Brown & Root's Fifteenth Set of Interrogatories to Houston Lighting & Power Co.

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• 07/02/84 4,6 HL&P Co.'s Twentieth Set of Interrogatories to B&R 07/09/84 Review All Answers Brown & Root's Sixteenth Set of Interrogatories to HL&P Company

• 07/20/84 Review All Answers Brown & Root. Inc.'s Seventeenth Set of j

Interrogatories to HL&P Co.

07/20/84 268.272 Brown & Root's Eighteenth Set of Interrogatories to HL&P Co.

07/23/84 Review All Answers HL&P Co.'s Twenty-First Set of Interrogatories to Brown & Root and Halliburton. Inc.

07/23/84 Review All Answers HL&P Co.'s Twenty-Second Set of Interrogatories to Brown & Root and Halliburton. Inc.

07/23/84 Review All Answers HL&P Co.'s Twenty-Third Set of Interrogatories to Brown & Root. Inc. and Halliburton. Inc.

07/23/84 Review All Answers HL&P Co.'s Twenty-Fourth Set of Interrogatories to Brown & Root and Halliburton. Inc.

07/23/84 Review All Answers ifL&P Co.'s Twenty-Fifth Set of Interrogatories to Brown & Root and Halliburton. Inc.

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1 ATTACHMENT 1 l

Procedure No. LRP-2 1 Revision 2 i 4

Page 45 of 49 l Date Issued: -

FEB 181953  !

Date Filed Questions to be Reviewed Items 07/23/84 Review All Answers HL&P Co.'s Twenty-Sixth Set of Interrogatories to Brown & Root and Halliburton, Inc.

07/23/84 Review All Answers HL&P Co.'s Twenty-Seventh Set of  !

Interrogatories to Brown & Root and Halliburton, Inc.,

07/23/84 Review All Answers HL&P Co.'s Twenty-Eighth Set of Interrogatories to Brown & Root and Halliburton, Inc.

07/23/84 Review All Answers NL&P Co. 's Twenty-Ninth Set of Interrogatories to Brown & Root and Halliburton Inc.

07/23/84 Review All Answers HL&P Co.'s Thirtieth Set of Interrogatories to Brown & Root and Halliburton, Inc.

07/23/84 Review All Answers ML&P Co.'s Thirty-First Set of i Interrogatories to Brown & Root and Halliburton, Inc.  !

07/23/84 Review All Answers HL&P Co.'s Thirty-Second Set of Interrogatories to Brown & Root and Halliburton, Inc.

07/23/84 Review All Answers NL&P Co.'s Thirty-Third Set of Interrogatories to Brown & Root and Halliburton Inc.

07/23/84 Review All Ar.svers RL&P Co.'s Thirty-Tourth Set of Interrogatories to Brown & Root and  !

Halliburton, Inc.

07/23/84 Review All Answers NL&P Co.'s Thirty-Fifth Set of Interrogatories to Brown & Root and l Halliburton, Inc.

07/23/84 4-7,24,25,26,28,29,30, City of San Antonio'( Fourth Request for I l 32,37,38,41,42,43,44, Admissions and Fifth Set of Interrogatories i

45,47 {

to Brown & Root, Inc.

l 07/30/84 Review All Answers HL&P Co.'s Thirty-Sixth Set of I

Interrogatories to Brown & Root, Inc.

08/08/84 Review All Answers Brown & Root's Nineteenth Set of Interrogatories to Houston Lighting & Power Company {

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ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 46 of 49 Date Issued: FEB 181936 Date Filed Ouestions to be Reviewed Items 08/08/84 Review All Answers Brown & Root's Seventh Set of Interrogatories to Central Power & Light Company 08/08/84 Review All Answers Brown & Root's Ninth Set of Interrogatories to City of Austin 08/08/84 Review All Answers Brown & Root's Seventh Set of Interrogatories to City of San Antonio

• 08/16/84 1,2,9,18,23 City of Austin's Tenth Set of Interrogatories to Brown & Root

• 08/20/84 134 Halliburton's Sixth Set of Interrogatories to HL&P Co.

08/20/84 132 Halliburton's Sixth Set of Interrogatories 1 to CP&L Co. '

08/20/84 120 Halliburton's Sixth Set of Interrogatories to the City of Austin 08/20/84 118 Ha111 burton's Sixth Set of Interrogatories ,

to the City of San Antonio l

1 08/21/84 Review All Answers Brown & Root's Tenth Set of Interrogatories to the City of Austin

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08/21/84 Review All Answers Brown & Root's Eighth Set of Interrogatories to CP&L Co. l 08/21/84 Review All Answers Brown & Root's Eighth Set of i Interrogatories to the City of San Antonio {

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09/10/84 Review All Answers NL&P Co.'s Thirt'y-Eighth Set of Interrogatories to Brown & Root. Inc. &

Halliburton 09/11/84 Review All Answers Brown & Root. Inc.'r Ninth Set of I Interrogatories to the cit;* of San Antonio

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09/11/84 Review All Answers i Brown & Root. Inc.'s Twentieth Set of  ;

Interrogatories to HL&P Co.

09/11/84

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Review All Answers Brown & Root. Inc.'s Eleventh Set of I Interrogatories to the City of Austin l

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ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 47 of 49 Date Issued: FEB 181926 Date Filed Questions to be Reviewed Items 09/11/84 Review All Answers Brown & Root, Inc.'s Ninth Set of Interrogatories to CP&L Co.

• 09/24/84 Review All Answers The City of Austin's Eleventh Set of Interrogatories to Brown & Root Inc.

, *09/24/84 Review All Answers The City of Austin's Twelfth Interrogatories to Brown & Root 09/26/84 Review All Answers Brown & Root's Twenty-First Set of Interrogatories to HL&P Co.

09/26/84 Review All Answers Brown & Root's Tenth Set of Interrogatories to the City of San Antonio 09/26/84 Review All Answers Brown & Root's Twelfth Set of Interrogatories to the City of Austin 09/26/84 Review All Answers Brown & Root's Tenth Set of Interrogatories to CP&L Co.

• 10/22/84 122,123,125,127,128 Ha111 burton's Seventh Set of

Interrogatories to City of Austin

• 10/22/84 136,137,138,140,144,145 Ha111 burton's Seventh Set of Interrogatories to HL&P

• 10/22/84 134,135,136,138,142,143 Ha111 burton's Seventh Set of Interrogatories to CP&L

• 10/22/84 120,121,122,124,128,129 Ha111 burton's Seventh Set of i

Interrogatories to City of San Antonio 11/14/84 48,49,51,52,53,55,56,57 City of San Antonio's Sixth Set of 59,60.61,63.64,65,67,68 Interrogatories to Brown & Root, Inc.

69,71,72,73,75,76.79,80, 81,83.85,88.91,92,94,95, 98,99,100,102,103.104, 106,107.108,110,111,112, 114.115.116 .

• 11/26/84 Review All Answers Brown & Root's Thirteenth Set of Interrogatories to Central Power & Light Ceepany '

01/23/85 Review All Answers Brown & Root's Inc.'s Amended Seventeenth Set of Interrogatories to Houston Lighting l

& Power Company

ATTACHMENT 1 Procedure No. LRP-2 Revision 2 Page 48 of 49 '

Date Issued: FEB 181926 Date Filed Questions to be Reviewed Items

• 02/11/85 122.,123,124,126,130 Ha111 burton's Eighth Set of Interrogatories to the City of Austin

• 02/11/85 120,121,122.124,128 Hal11 burton's Eighth Set of Interrogatories to the City of San Antonio

• 02/11/85 134,135.136,138,142 Halliburton's Eighth Set of Interrogatories to Central Pcwer & Light Company

'92/11/S5 136(p.4),137(p.5), Halliburton's Eight Set of Interrogatories 136(p.6),138(p.6),142 to Houston Lighting & Power Company 02/13/85 Review All Antwers Brown & Root, Inc.'s Twenty-Fourth Set of Interrogatories to Houston Lighting & Power Company

'02/13/85 Review All Answers Brown & Root, Inc.'s Fourteenth Set of Interrogatories to Central Power & Light Company i *02/19/85 Review All Answers i Houston Lighting & Power Company's Thirty-Ninth Set of Interrogatories to Brown & Root, Inc.

• 03/13/85 12,13,14,17,20-28 RL&P's Fortieth Set of Interrogatories t

• 03/22/85 Review All Answers Brown & Root, Inc.'s Fifteenth Set of

. Interrogstories to the City of San Antonio 03/22/85 Review All Answers Brown & Root, Inc.'s Twenty-Sixth Set of Interrogatories to Houston Lighting & Power Company

• 03/22/85 Review All Answers Brown & Root, Inc. 's Fif teenth Set of Interrogatories to Cer. tral Power & Light

?

Co.

• 03/22/85 Review All Answers Brown & Root. Inc.'s Seventeenth Set of Inte.rrogatories to the City of Austin

• 04/26/85 125-128,130-133,136, City of San Antonio's Seventh Set of 138-142 Interrogatories to Brown & Root. Inc.

04/29/85 Review All Answers Brown & Root's Twenth-Eighth Set of Interrogatories to Houston Lighting & Power Company I

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1 ATTACHMENT 1 Procedure No. LRP-2 Revision'2 Page 49 of 4%8181926 '

Date Issued: '

Date Filed Questions to be Reviewed FEB 151986 Items

• 04/29/85 Review All Answers Brown & Root's Nineteenth Set of  !

Interrogatories to the City of Austin l

• 04/29/85 Review All Answers Brown & Root's Seventeenth Set of Interrogatories to Central Power & Light Company

• 04/29/85 Review All Answers I Brown & Root's Seventeenth Set of Interrogatories to the City of San Antonio l l

• 05/09/85 Review All Answers Houston Lighting and Power Company's Forty-First Set of Interrogatories to Brown  ;

& Root 1 05/13/85 Review All Answers Brown & Root's Twenty-Ninth Set of <

Interrogatories to Houston Lighting & Power Company

• 05/15/85 461,465 Brown & Root, Inc.'s Thirtieth Set of Interrogatories to KL&P l

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Procedure LRP-3 Revision 1 Page 1 of 4 Date Issued E0V 151985 S. Levy Incorporated Review of HL&P y BAR Litigation Record - Subject Groupings - LRP-3 Sumary of Revisions Revision No. Revision Description Rev. O Initial Issue Rev. 1 Two categories added to allow computer sorting in special situations.

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i Revision Authorization Date Revision No. 1

/1 Date Issued -

~

,V 15 192 .

Approved by (SLI) d[ y gf4gg Reviewed by u

(SLIQA) N4/Ff Approved by -

n h3 g(

(HL&P Licensing) , /) ..Q U

N lear A u an e) -

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l S. LEVY INCORPORATED l

Procedure No. LRP-3 '

Revision 1 Page 2 cf 4 Date Issued ?!0V 151985 i l

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Title:

Review of HL&P v B&R Litigation Record i

Subject:

Subject Groupings The list of subject categories and their designators are. enclosed on  ;

pages 2 and 3. i The Reviewers may, as needed in the course of their work, request addi-tions to this list through the Team Leader.

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Procedure No. LRP-3 Revision 1 Page 3 of 4

'Date Issued NOV 1 5 1985 STP LITIGATION REVIEW CATEGORY LIST DESIGNATOR DESIGNATOR DESCRIPTION

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MECH Mechanical Systems

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CCW Component Cooling Water System HVAC NSSS Heating, Ventilating and Air Conditioning Other NSSS PIPE RADW Piping, supports, restraints, stress Radwaste systems REPH SGBS Reactor including Physics <

TNKS Steam Generator Blowdown System Tanks WELD Welding, technology, procedures {

VLVS Valves

.ELS Electrical Systems BATT DC Batteries BUS TRAF AC/DC buses, Motor Control Centers Transformers TRAY Cable Trays I&C Instrumentation and Controls C&S Civil and Structural ANCB CONC Anchor Bolts /Embedment Plates CONE Concrete, rebars, voids DGB Construction equipment including cranes FNDT Diesel Generator Bldg., C&S Four,dations FSB IVC Fuel Storage Bldg., C&S MEAB Isolation Valve Cubicle P&C Mech. & Elec. Aux. Bldg., C&S RCB Paintings & Coatings RES Reactor Containment Bldg., C&S STAN Reservoir including Penetrations Stress Analysis with C&S TGB Turbine Generator Bldg., C&S

Procedure No. LRP-3 Revision 1 Page 4 of 4 Date Issued NOV 1 5 1985 STP LITIGATION REVIEW CATEGORY LIST DESIGNATOR DESIGNATOR DESCRIPTION SITE Site and Environment EXC Excavations HYD Hydrology MET Meteorology SEIS Seismology XXXX Other designators in the above list do not suf-ficiently define this Assertion category.

Rev. 1 AAAA Some information appears to be incomplete or incor-porated by reference only. (Not for Assertions but to define scope questions for subsequent action.)

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Procedure No. LRP-4 Revision 1 Page 1 of 25 Date Issued " 3 1985 S. Levy Incorporated Review of HL&P y BAR Litigation Record SAMPLE EVALUATIONS OF WORK PRODUCTS AND PREPARATION OF SHIPMENT OF DOCUMENTS.- LRP-4 Sumary of Revisions  !

l Revision No. Revision Description l

Rev. O Initial Itsue )

Rev. 1 Revisions to Section 1.4, 2.4 and 2.5 and minor changes to forms SUR-4 and 6 I

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1 Revision Authorization

)

Date 1 Revision No. 1 Date Issued DEC 3 1985 Approved by (SLI) . ew k.2j MW Approved by (SLI QA)

~~

' /s) a ;) pf v ~

Approved by (HL&P Nuclear Licensing) h "

L( 7 t. Pf Approved by (HL&P G f

Nuclear Assurance) - .

, 3/pf l

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-w,-----w - - - - - + - . - +-y.-w-ym

l S. LEVY INCORPORATED Procedure No. LRP-4 Revision 1 Page 2 of 25 Date Issued DEC 3 1985

Title:

Review of HL&P v B&R Litigation Review

Subject:

Sample Evaluations of Work Products and Preparation for Shipment of Documents

1. EVALUATION OF THE REVIEWER'S WORK 1.1 Purpose To provide procedures for conducting an evaluation of the' Reviewers' work products under the STP Litigation Review.

1.2 Scope This procedure will be adhered to by any Evaluator assigned to conduct sample evaluations of the Reviewer's work. Instructions for the originating Reviewer's response are also provided.

1.3 Objective To obtain assurance that assertions are correctly identified and recorded, and that the work complies with the procedures and criteria established for the Reviewers under the Project Plan.

1.4 Policy The accuracy of assertions recorded by the Reviewer will be verified on a sample basis.

A sample of each Reviewer's early work product shall be evaluated. g g,o 3 The Team Leader will identify additional evaluations required and 4 will assign evaluating personnel.

The Evaluator must be an individual different from the Reviewer and i must Leader.have qualifications equivalent to those required of the Team [ R s.O 1 l 1

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Procedure No. LRP-4 Revision 1 Page 3 of 25 Date Issued DEC 3 1985 1.5 Evaluation Procedure The evaluation work cannot be initiated until the Reviewer has fully completed and filed the work product to be reviewed as defined in LRP-1 and the Guidance document.

i The Evaluator and the specific document to be reviewed are assigned I by the Team Leader.

The Evaluator will conduct a review of the assigned document. In  ;

the process he will complete the enclosed questionnaire (SUR-1) l which, when finished, will constitute his complete findings. Under i each section of the questionnaire he shall number his findings (under Section 3, as an example, he would use nos. 3.1, 3.2, etc.)

The Evaluator shall review his findings with the originating Reviewer. '

I The originating Reviewer shall respond to all findings as indicated on the enclosed form (SUR-2). The response may be a written com- j ment or a correction / addition to the original Assertion Form. In  !

the latter case a copy of the corrected or revised Assertion Form,  !

signed-off by the originating Reviewer, shall be attached to SUR-2.

The originating Reviewer shall turn over the completed SUR-1 and SUR-2 forms to the QA Specialist assigned to the STP Litigation j Review.

The QA Specialist shall review the documents for compliance with this procedure and complete the enclosed form SUR-3.

At this point the Team Leader shall review the documents to main-tain cognizance of Reviewers' performance and shall sign-off on Form SUR-3.

The QA Specialist shall attach SUR-3 as the top sheet to the SUR-1 and SUR-2 forms and arrange for filing in order of the Deposition no./ volume no. (0023-Yol. I, etc.). ,

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Procedure No. LRP-4 Revision 1 Page 4 of 25 Date Issued DEC 3 1985 The SLI Team Leader will be the ultimate referee in case of disagreements between the Evaluator and the originating Reviewer.

Any such discussion with-the Team Leader shall be conducted prior to final sign-offs on SUR-2.

Forms SUR-1, SUR-2 and SUR-3 shall be signed-off. [',_ EEL'/ dL 1

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Procedure No. LRP-4 '

Revision 1 Page 5 of 25 Date Issued DEC 3 1935 EVALUATION OF ASSERTIONS FINDINGS Document No. , Document Title Document Date Deposition Vol. No.

Evaluator's Name Date Completed i

Evaluator's Signature FINDINGS PERTAINING TO ASSERTIONS:

1. Were all assertions identified by the Reviewer? (List any possible additional assertions)

2. Did the Reviewer identify assertions that the Evaluator believes are not assertions? (List any such assertions)

3. Were assertions accurately described? (List any specific suggestions for improving accuracy)

FormSURd,Page1of3

Procedure No. LRP-4 Revision 1 Page 6 of 25 DateIssuednEt 3 1985 EVALUATION OF ASSERTIONS FINDINGS (CON'T)

4. Were all factual data accurately entered? (Doc. No., Dates, Page No./Line Nos., etc.)

5. Were the Assertion Forms properly signed-off?

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6. Did the Reviewer make appropriate annotations in the margin?

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l QUESTIONS PERTAINING TO NRC CITINGS

7. Did the Reviewer locate all references to allegations concerning NRC competence or performance? (List any additional items found)

Form SUR-1, Page 2 of 3

Procedure No. LRP-4' Revision 1 Page 7 of 25 Date Issued DEC 3 1985 EVALUATION OF ASSERTIONS FINDINGS (CON'T)

8. Did all NRC citings found c6ntain elements of a judgemental nature?

(Trivial references not required)

9. Were the NRC references correctly identified? (Dep. No., Dep. Date,

, Page No./Line Nos.)

10. Was the NRC Citing Form signed-off?

11. Date of discussion with the original Reviewer:

The Evaluator'may, if necessary, attach additional pages.

' 12. Number of pages attached to this SUR-1:

BE SURE THAT ALL FINDINGS ARE NUMBERED Form SUR-1, Page 3 of 3

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Procedure No. LRP-4 Revision 1 Page 8 of 25 Date Issued DEC 3 1985 EVALUATION OF ASSERTIONS ORIGINATING REVIEWER'S RESPONSE Document No. Document Title Document Date .

Deposition Vol. No.

Evaluator'r Reviewer' e_

Date Completed Reviewer , sign.. are L

In the space provided below respond to all findings produced.by the Evaluator, using his numbering system for easy reference. If you have changed or added any assertions, so state and attach a copy of the revised Assertion Form (s).

Evaluator Evaluator's Agreement Ref. No. Response (Initial)

Form SUR-2, Page 1 of 2 ,

Prccedure No. LRP-4 I Revision I l Page 9 of 25 Date Issued DEC 3 1985 EVALUATION OF ASSERTIONS  ;

ORIGINATING REVIEWER'S RESPONSE I

i (Continuation Sheet)

Evaluator Evaluator's Agreement i Ref. No. Response (Initial)  !

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Form SUR-2, Page 2 of 2 l

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Procedure No. LRP-4 Revision 1 Page 10 of 25 l

Date Issued DEC 3 1985 EVALUATION OF ASSERTIONS CLOSURE Document No. Document Title Document Date Deposition Vol. No.

Evaluator's Name Originating Reviewer's Name QA Specialist's Name QA Specialist's Signature l

1 Management Sign-Off Date Team Leader's Signature 1

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Form SUR-3 Page 1 of 1 i

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Procedure No. LRP'-4 Revision 1 Page11 of 25 Date Issued i' 2 1935

2. EVALUATION OF THE SPECIALISTS' WORK 2.1 Purpose To provide procedures for conducting an evaluation of the work pro-duced by the Discipline Specialists and the Overview Specialists.

Both types of specialists will conclude their work using the same g,j, j form (see Form DIS-01, Guidelines Fig. 2 in Tab 3).

The word " Specialist," when used in this procedure, shall mean either the Discipline or the Overview Specialist, and this proce-dure shall apply to both.

2.2 Scope l

l This procedure will be adhered to by any Evaluator assigned to con- I duct sample evaluations of the Specialist's work. Instructions for the originating Specialist's response are also provided.

2.3 Objective To provide assurance that the disposition stated on the Disposition Form are substantially correct and comply with the criteria and l procedures established for the work of the Specialist under the Project Plan.

2.4 Policy The appropriateness of dispositions arrived at by the Specialist l will be verified on a sample basis. l A sample of each Specialist's early work product shall be eval- "

uated. The Team Leader will identify additional evaluations [* T.1 !

required and will assign evaluating personnel. "

The Evaluator must be an individual different from the Specialist and have qualifications equivalent to those required of the Team "'

Leader.

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l Procedure No. LRP-4 Revision 1 Page 12 of 25 Date Issued DEC 3 1985 i

2.5 Evaluation Procedure 1 l

The evaluation work cannot be initiated until the Specialist has i fully completed and filed the work product to be reviewed as defined in the LRP-1 procedure and the Guidance document.

The Evaluator and the specific Disposition Forms to be reviewed are l assigned by the Team Leader.  !

The Evaluator will conduct a review of the assigned Disposition Forms. In the process he will complete the enclosed questionnaire (SUR-4) which, when finished, will constitute his complete fin-dings. Under each section of the questionnaire he shall number his  !

findings (under Section 2, as an example, he would use nos. 2.1, 2.2, etc.).

The Evaluator shall review his findings with the originating Specialist.

The originating Specialist shall respond to all findings as indi-cated on the enclosed form (SUR-5). The response may be a written comment or a correction / addition on a copy of the original "

Disposition Form. He will then prepare a SUR-6 Form and deliver the entire document package to the Team Leader.

At this point the Team Leader shall review the documents to main-tain cognizant of Specialist's performance and sign-off on Form SUR-6. He will then forward the documents to SLI-QA.

A QA Specialist assigned by the Manager of Quality Assurance shall l review the documents for compliance with this procedure. After his '

sign-off, he will return the entire package to the originating Specialist.

The originating Specialist shall have all agreed upon changes exe- )

cuted and the document package returned to Records. g )

The SLI Team Leader will'be the ultimate referee in case of disagreements between the Evaluator and the originating Specialist. l Any such discussion with the Team Leader shall be conducted prior I to final sign-off on SUR-5.

Forms SUR-4, SUR-5 and SUR-6 shall be signed-off. Ad 1

l Precedure No. LRP-4 Revision 1 Page 13 of 25 l l

l Date Issued DEC 3 1985 EVALUATION OF DISPOSITIONS FINDINGS ,

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Disposition No.

• Completion Date (This form applies to only one disposition)

Evaluator's Name Date Completed Evaluator's Signature 1

OVESTIONS PERTAINING TO THE AB0VE DISPOSITION:

)

1. Does the Disposition statement completely cover all assertions 1 listed on the Disposition Form? (Yes/No or comments as necessary) l l

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2. Was the disposition statement by the Specialist appropriate? (List any specific suggestions for improving the disposition statement)

Form SUR-4, Page 1 of 4

Procedure No. LRP-4 Revision 1 Page 14 of 25 Date Issued DEC 't 1985 EVALUATION OF DISPOSITIONS FINDINGS (CONT'D)

3. Were the STP documents correctly referenced, including document revision levels? (Compare references on the Disposition Form with,_ g f the actual documents)

4. Were the assertion (s) judged by the Specialist to be: (Check at least one of the following: "Y" for Yes and "N" for No)

- Fully covered by STP documentation?

Not safety-related?

Factually erroneous?

Safety-related and not fully covered by STP documents? (and a DEF prepared)

Correctly dispositioned as not an assertion of a "~

deficiency in accordance with " Criteria for Iden- g), I tificolion of Assertion of Deficiency." See LRP-1. .

5. Explain in a few words the reasons for any disagreement with the Specialist's disposition.

Form SUR-4, Page 2 of 4

Procedure No. LRP-4 Revision 1 Page 15 of 25 Date Issued DEC 3 1985 EVALUATION OF DISPOSITIONS FINDINGS (CONT'D) 6.

Wereallthefactualdataaccuratelyentered,includingSTPdocument.ygggJ revision level? (Assertions nos., Disposition no., Dates, etc.) ,_

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7. Was the Disposition Form properly signed-off? 1 OVESTIONS PERTAINING TO DISPOSITIONS BY THE OVERV'IEW SPECIALIST ONLY

8. State the disposition number used by the Discipline Specialist. i 1

9. Did the Discipline Specialist in fact classify this disposition as not safety-related? )

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10. Did the Overview Specialist identify all potential safety-related interactions? (In your judgment there may be other potential safety-related interactions, if so, discuss below.)

Form SUR-4, Page 3 of 4

Procedure No. LRP-4 Revision 1 Page 16 of 25 Date Issued DEC 3 1985 EVALUATION OF DISPOSITIONS FINDINGS (CONT'D)

11. Should other Overview Specialists be called upon to assist in establishing the potential for safety-related interactions? If so, what area of expertise?

1

12. Date of discussion with the Overview Specialist:  ;

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The Evaluator may, if necessary, attach additional pages. l

13. Number of pages attached to this SUR-4: l 1

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Form SUR-4, Page 4 of 4

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Precedure No. LRP-4 l Revision 1 1 Page 17 of 25 l hte Issued DEC 3 1985 EVALUATION OF DISPOSITIONS ORIGINATING SPECIALIST'S RESPONSE 1

Disposition No. Completion Date Evaluator's Name Specialist's Name l

Date Completed Specialist's Signature i I

^

In the space provided below respond to all findings by the Evaluator, <

using his numbering system for easy reference. If you have revised the l disposition, so state and attaen a copy of the revised Disposition  !

Form (s). l l

Evaluator I Evaluator's Agreemenc l Ref. No. Response (Initial) I I

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l Form SUR-5, Page 1 of 2

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Procedure No. LRP-4 Revision 1 Page 18 of 25 Date Issued DEC 3 1985 EVALUATION OF DISPOSITIONS ORIGINATING SPECIALIST'S RESPONSE 1

(Continuation Sheet) l Evaluator Evaluator's Agreement .

Ref. No. Response (Initial) i I

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Form SUR-5, Page 2 of 2

Procedure No. LRP-4 Revision 1 Page 19 of 25 Date Issued DEC 3 1985 EVALUATION OF DISPOSITIONS CLOSURE Disposition No. ' Completion Date Evaluator's Name Specialist's Name

! QA Specialist's Name a-

@c41 Management Sign-Off Date Team Leader's Signature QA Specialist's Signature Date 130./ }.

Form SUR-6

Procedure No. LRP-4 Revision 1 Page20 of 25 Date Issued DEC 3 1985

3. EVALUATIONS DURING PREPARATION OF THE FINAL REPORT 3.1 Report Content The report will be subdivided into text and Data Base material as follows:

A. Text (Report Outline)

Executive Summary Introduction Purpose Scope Methodology used Chronological Project Review Sumary of Results B. Appendices (Data Base generated)

Detailed listings which will include:

Materials reviewed Assertions and Dispositions Reviewer's and Specialist's names i NRC Citing Listings DEF's forwarded to HL&P The following Sections 3.2, 3.3 and 3.4 will define the evaluations to be conducted to assure that the report will be correct, con-sistent, complete and accurate.  ;

3.2 Evaluation of the Text l j

Prescribed portions of the text will be assigned to individuals for preparation and entry into the word processor system. When the originator is satisfied with the word processor output he will pre-pare a clean finished galley proof with all figures and tables.

The galley proof will be formally reviewed by an assigned indivi-dual against written criteria and check lists (to be furnished by the Team leader). Findings w.ll be recorded. The originator will resolve all findings with the report reviewer. The resolution will be documented in the form of a new clean galley proof and signed by '

both the originator and the report reviewer. The records of the i

Procedure No. LRP-4' Revision 1 Page21 of 25 Date Issued DEC 3 GS5 i

review will be reviewed by the QA specialist and the Team Leader for compliance with the procedures.

3.3 Evaluation of the Appendices General Instructions The Appendices consist of the data base generated portions of the report. This material will be reviewed for both completeness and accuracy. Individuals assigned to these reviews will document their findings and report to the Team leader who in turn, together with Records and Computations management, will determina and docu-ment causes, remedial actions and non-reoccurrence steps to be taken. All records of these reviews will be retained by Records

' management after approval and sign-off by the QA Specialist and the Team Leader.

~

Completeness Using galley proofs of the Data Base generated listings the report reviewer shall: ,

- Check that all materials reviewed that are listed on the galley proofs are in fact located in the Records Management files. This check includes all volumes within each deposition transcript.

Both the files containing originally received documents and the files containing the reduced size and annotated copies must be checked.

- Check that an NRC Citing Form has been completed and filed for each document reviewed.

- Verify the following:

a. Check that all originals of the completed Assertion Forms and DispositionT6rms are in fact located in their respective Records Management files,

b. The Data Base listing will only show the last revision of Assertion Forms and Disposition Forms. Check that one hard copy of all previous revisions is located (sequentially) at the appropriate file position.

Procedure No. LRP-4 Revision 1 Page21 of 25 Date Issued DEC 3 1335 review will be reviewed by the QA specialist and the Team Leader for compliance with the procedures.

3.3 Evaluation of the Appendices General Instructions The Appendices consist of the data base generated portions of the  !

report. This material will be reviewed for both completeness and I accuracy. Individuals assigned to these reviews will document I their findings and report to the Team leader who in turn, together with Records and Computations management, will determine and docu- i ment causes, remedial actions and non-reoccurrence steps to be '

taken. All records of these reviews will be retained by Records management after approval and sign-off by the QA Specialist and the l Team Leader.

Completeness Using galley proofs of the Data Base generated listings the report reviewer shall: .

- Check that all materials reviewed that are listed on the galley proofs are in fact located in the Records Management files. This check includes all volumes within each deposition transcript.

Both the files containing originally received documents and the files containing the reduced size and annotated copies must be checked.

- Check that an NRC Citing Form has been completed and filed for each document reviewed.

- Verify the following:

a. Check that all originals of the completed Assertion Forms and Disposition T6rms are in fact located in their respective Records Management files.

b. The Data Base listing will only show the last revision of Assertion Forms and Disposition Forms. Check that one hard copy of all previous revisions is located (sequentially) at the appropriate file position.

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Procedure No. LRP-4 j Revision 1

Page22 of 25 Date issued DEC 31985

, c. Check that all actual Assertion Forms and Disposition Forms in fact appear in the Data base listing.

Accuracy On a sample basis assigned report reviewers will compare-the Data base listing with the actual Assertion Forms, Disposition Forms or NRC Citing Forms for accuracy of the following data:

Assertion Forms Dispositions Forms

- Document no. -

Doc. No./ assertion nos

- Assertion no. - Disposition no

- Docua nt Title - Specialist Name

- Reviewer name -

Status (final)

- Date completed -

Date completed

- Document Date -

Correct signature

- Deposition Vol. No

,- - Page No/Line No. (from NRC Citing Forms actual document)

- Disposition No. or -

Document No.

Overview Disp. No. (Long- -

Document table hand entry) -

Reviewer name

- Correct signature -

Reviewer signature Date completed Page No/line No. (actual doc.)

Vol. No. (

) '

3.4 Total Report Review The reviewers assigned to review the total report will assure that:  !

- The statements made in the text are mutually consistent

- The total scope, as defined in the Project Plan, has been addressed

- All references are correct, including text references to figares i

and tables and references to the Appendix material.

This review takes place after completion of the reviews under

' Section 3.3 above and after completion of the corresponding above i galley proofs, which become the basis for the total report review. l l

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Procedure No. LRP-4 Revision 1 l Page23 of 25 Date Issued DEC 3 1985 i

Results of the review will be managed, documented and retained as  !

described under Section 3.2 above. )

3.5 Review of Production Copies Sample copies of the final report will be compared to the final galley proofs after the review under Section 3.4 above.

)

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i Procedure No. LRP-4

. Revision 1 Page 24 of 25 Date 1ssued CEC 3 1985 l

4. PREPARATION FOR SHIPMENT OF DOCUMENTS 4.1 General When the project is complete and when the final report is issued, all documents received and a copy of all controlled documents

)

generated will be returned to HL&P for permanent storage. HL&P '

will indicate the exact date of shipment desired. This final docu-ment transfer must be carefully prepared and managed.

4.2 Scope o 1 copy final report o 1 copy Project Plan and procedures ,

l o Deposition transcripts received, including exhibits i o Expert reports o Interrogatory answers o IRC Files .

l o Other STP documents received o Annotated reduced (size) copies of materials reviewed together with the attached Assertion Forms.

i o Disposition Forms together with attached references etc.

o Files of QA documentation o 1 copy of the SLI QA manual o Training record files o Program Chronological ~ File o Other controlled document files o Total document listing '

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1 Procedure No. LRP-4 Revision 1 ,

Page 25 of 25 l 1

Date Issued DEC 3 1985 4.3 Preparation for Shipment ,

Prepare listings of all documents to be shipped. Computer data  !

base listings may be used if applicable.  !

)

Number each shipment box and indicate on the above listing in which '

box tne document is located.-

1 In addition to the box number, attach a list to the box of its  !

exact contents. Use sections of the computer data base listing as '

applicable.

Place the box number and the contents listing on the same location l for each box; usually on the "beginning" end of the box. Never on the lid.

Example format:

STP LITIGATION REVIEW (1985-1986)

Conducted by S. Levy Incorporated Under HL&P P. O. Number BOX NO. XXX Contents l

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' Procedure No. LRP-5 Revision 2 Page 1 of 15 Date Issued FEB 181956 S. Levy Incorporated Review of HL&P v B&R Litigation Record QA AUDITS, SURVEILLANCES AND REVIEWS - LRP-5

,- Sumary of Revisions Revision No. Revision Description Rev. O Initial Issue Rev. 1 Clarify Responsibilities and Reviews Sections

'Rev. 2 Added Section 5.5, Qualification and Certification of QA Auditors

\

Revision Authorization Date Revision No. 2 Date Issued FEB 181956 s _

Approved by (SLI) ,

y mi ad JL ~vn

, -- . ~ . -

Approved by (HL&P C l ~

Nuclear Licensing) 3 /

2/ ~7/W Approved by (HL&P gj 74 Nuclear Assurance)

I l l l e

l S. LEVY INCORPORATED Procedure No. LRP-5 Revision 2 Page 2 of 15 Date Issued FEB 1813?6

Title:

Review of HL&P v B&R Litigatic7 Record  ;

Subject:

QA Audits, Surveillances and Reviews 1.0 PURPOSE l

To provide instructions and define responsibilities for the con-  !

duct, reporting and follow up of audits, surveillances and reviews.

2.0 SCOPE This procedure applies to activities required by and delineated in the Project procedures, guidelines and instructions, including:

reviewing litigation record materials, preparing Assertion Forn.5,

. compiling and grouping assertions, dispositioning assertions, and reporting results.

3.0 DEFINITIONS ~

Audit - An activity to determine through investigation, the ade-quacy of, and adherence to, established procedures, instructions, specifications, codes, and standards or other applicable contrac-tual and licensing requirements, and the effectiveness of implemen-tation.

Audit Team Leader - An individual qualified to organize and direct an audit, report audit findings and evaluate corrective action.

Surveillance - An examir.ation, observation or inspection for the purpose of verifying that an action has been accomplished as spe- l cified by procedures, guidelines or instructions. (Where there is '

a process involved, an assessment of completeness and consistency may also be made.)

Review - A critical evaluation of documentation to determine its conformance to objective acceptance criteria, i.e., procedures, guidelines, instructions, specifications, etc. (Where there is a process involved, an assessment of completeness ~and consistency may be made.)

Audit Finding Report (AFR) Att. A - A form used to document the requirement against which the finding is written, the discrepancy detected, and the auditor's recommendation for corrective action.

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Procedure No. LRP-5 Revision 2 Page 3 of 15 Date Issued FEB 18198G q

4.0 REFERENCES

l ANSI N45.2.12, Requirements for Auditing of QA Programs for Nuclear Power Plants ANSI N45.2.23, Qualification of QA Audit Personnel for Nuclear Power Plants l

LRP-6, Deviation Reporting and Action Item Requests  !

5.0 PROCEDURE  ;

i 5.1 Responsibility l The QA Manager will generate an Audit, a Surveillance, and a Review Schedule and will assign QA personnel to conduct audits, sur-veillances and reviews. Personnel assigned to audits as Lead Auditors must be qualified in accordance with the requirements of ANSI N45.2.23. Personnel assigned to Surveillances and Reviews must be qualified as auditors in accordance with the requirements i of ANSI N45.2.23. These personnel shall have had prior QA work experience.

5.1.1 The Audit Team Leader is responsible for:

a. Reviewing the current Audit Schedule, as necessary, to ensure that assigned audits are performed as scheduled,

b. Coordinating team activities in the preparation, performance, reporting, and follow up for assigned and scheduled audits.

c. Performing those functions required by this procedure.

5.1.2 The Audit Team Members are respon'sible for: I Performing those functions assigned by the Audit Team Leader and required by this procedure. a 5.1.3 QA personnel assigned to perform surveillances and reviews are responsible for: ~'

Performing the functions required by this procedure.

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Procedure No. LRP-5 Revision 2 Page 4 of 15 Date Issued FEB 181926 1 1

5.2 Audits '

5.2.1 Preparation for the Audit  :

l The assigned Audit Team Leader consults the Audit Schedule to 1 establish the scope, scheduled dates, contacts, and assigned Audit Team Members. The Audit Team Leader then prepares an Audit Plan  ;

that specifically-identifies the Project Procedures, Guidelines,  !

instructions, contract requirements, NRC Commitments, and other l considerations, such as previous audits and surveillances, to be included as basis for the audit. The Audit Team Leader then meets l with the Audit Team Members and directs preparation of audit checklists based on the applicable requirements identified in the Audit Plan. The audit checklists will identify attributes to be verified and documents to be reviewed. The audit checklists will provide space for identifying documents actually reviewed, results and actions taken. The audit checklists thus prepared are reviewed by the Audit Team Leader and approved by the Corporate-QA Manager.

The Audit Team Leader notifies the organization to be audited in writing, at least five (5) days in advance of the entrance inter-view. The notification identifies: the scheduled dates, Audit Team Leader, time and place of the pre-audit meeting, and the scope of audit. The Audit Team Leader may also include the Audit Plan.

5.2.2 Performance of the Audit The Audit Team Leader:

Conducts a pre-audit meeting with individuals from the organization to be audited, explaining the scope of the audit.

Coordinates the performance of the Audit Team Members, emphasizing the scope of the audit. ,

Keeps the audited organization fully informed of discrepancies detected during the audit. Verifies that detected discrepancies are correct, and clears up misundarstandings or misinterpretations ,

on the part of the auditor and audited organization.

~

ReviewsanddiscussesresultswiththeAuditfeamMembersandmakes the final determination of the audit findings and observations prior to the post-audit conference.

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)

Procedure No. LRP-5 i

Revision 2 Page 5 of 15 Date Issued FEB 181cgg Conducts a post-audit conference with members of the audited orga-nization. During this meeting, the Audit Team Leader:

Identifies and discusses the audit' findings and recommendations for corrective action.

Identifies and discusses the audit observations and recommendations.

The Audit Team Leader prepares an Audit Finding Report (AFR)

(Attachment A) for each audit finding, and summarizes audit observations in the Audit Report. The AFR identifies the require-ments against which the finding is written, the discrepancy detected, and the auditor's recommendations for corrective action.

If, during the processing of the AFR, it is~ determined that the AFR may be reportable under 10CFR21 requirements, the AFR is sent'to the Team Leader and processed according to QAPP 16-2, S. Levy Incorporated Quality Assurance Program Manual, with the deletion of the following sentence in Section 5.1: "For purposes of complying with this Procedure, all Project Staff are instructed to report promptly to the Project Leader any anomalous software or test data, or equipment malfunctions."

5.2.3 Reporting the Audit The Audit Team Leader prepares an Audit Report based on the completed checklist (s), the pre-audit meeting, the post-audit con-ference, and any audit findings and. observations. .The Audit Report includes the following:

Scope of audit.

Synopsis of results. .

Summary of the audit, including:

a. Positive factors noted of the audited organization.

b. General comments presented by the audited organization.

c. Follow up on previous open addit findings.

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Procedure No. LRP-5 Revision 2 Page 6 of 15  ;

1 Date Issued FEB 18 iggg '

d. The number and general content of audit findings, description of observations and reconnendations, and a general evaluation )

of the effectiveness of implementation of the QA Program ele- I ments audited. I

e. General recommendations to improve QA Program implementation. ,

1 Administrative Data - indicating names of Audit Team Members and persons contacted during the audit.  ;

Copies of each Audit Finding Report are attached to the Audit Report. '

I 5.2.4 AFR Closeout and Audit Follow Up

{

Corrective action to closeout AFRs is scheduled and assigned for resolution by the Team Leader to be consistent with Project requirements. Verification of Corrective Action will be carried out. Where warranted by the severity of the deviations, a follow up audit, surveillance or review may be scheduled to confirm the adequacy of the corrective action.

5.2.5 Audit Records All audit documentation is processed in accordance with the Project Plan and the Document Processing Matrix.  ;

5.3 Surveillances 5.3.1 The QA personnel assigned to perform surveillances consult the i Surveillance Schedule to es'ablish the scope, scheduled dates, and contacts. Detailed checklists are required. The checklists will identify attributes to be examined and documents to be

' reviewed. The checklists will provide space for identifying documents actually reviewed, results, and action taken. l 1

I 5.3.2 A surveillance is conducted in the same manner as an audit except that the scope is usually na.rrower (e.g., limited to a single activity rather than a whole project), and formalities are reduced (e.g., no requirement for: written notification; formal entrance'and exit meetings; preparation of a detailed report;-

and, issuance of AFRs).

Procedure No. LRP-5 Revision 2 Page 7 of 15 Date Issued FEB 18 1986 5.3.3 A sumary report is prepared and issued. This report will cover the scope of the surveillance, synopsis of results, and the I number and general content of surveillance findings and an eva-luation of the effectiveness of the implementation of the QA Program elements surveyed.

5.4 Reviews

. 1 5.4.1 Reviews performed on Project documentation utilize prepared checklists. The checklists will identify attributes and docu-ments to be reviewed. The checklists will provide space for identifying documents actually reviewed, results and actions taken.

5.4.2 A review is conducted in a manner similar to a surveillance.

Reviews involve compliance, completeness and consistency con-siderations.

5.4.2.1 Compliance Formal Project requirements are detailed in procedures, guide-lines and instructions. Checklists are prepared whereby each individual requirement and commitment is identified. Compliance to the Project requirements and commitments, as sumarized on the checklists, is assessed and documented.

5.4.2.2 Completeness In addition to strict compliance to Project requirements, where applicable, an assessment is made of the completeness of the work process.

l 5.4.2.3 Consistency 1

Where applicable, an assessment is also made of the consistency I of_the engineering review or evaluation process.

5.4.3 A review report is prepared and issued. The report will cover the scope of the review, synopsis of results, the DRs and AIRS issued during the review, and the number and general content of review findings. i

'l

Procedure No. LRP-5 Revision 2 Page 8 of 15 Date Issued FEB 181998 5.5 Qualification and Certification of QA Auditors QA Auditors are qualified and certified by the SLI Corporate QA Manager in accordance with this procedure which responds to the requirements and guidance contained in ANSI N45.2.23. Auditors may be qualified and cer-tified based on their record from a previous employer (e.g., a new SLI employee) or an outside employer (i.e., a resident contract consultant).

the process is outlined below.

5.5.1 Review of Auditor's Qualifications - Checklist 1 Conduct a review of the Candidate's records for:

Experience and Training (ANSI N45.2.23, Section 2.2)

Competence demonstrated by:

Orientation to provide a working knowledge and understanding of ANSI N45.2, N45.2.23, and SLI procedures.

OR,Trainingprogramstoprovidegeneraiandspecialized training in audit performance.

OR, On-the-job training, guidance and counseling under the direction of a Lead Auditor.

If the candidate's records indicate the above, he may be cer-tified as an SLI Auditor.

5.5.2 Review of Lead Auditor's Qualifications - Initial Certification -

Checklists 1 and 2 Review candidate's records completing the designated checklists. i Review for the following requirements:

Education and Experience (ANSI N45.2.23, Section 2.3.1)

Communications Skills (Section 2.3.2) ,

1 Training (Section 2.3.3) -- '

Audit Participation (Section 2.3.4)  ;

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l Procedure No. LRP-5 Revision 2 Page 9 of 15 Date Issued FEB 181926  !

.l Examination (Section 2.3.5) 1 If the candidate meets the above-noted requirements for initial i certification, he may be certified as an SLI Lead Auditor.

l 5.5.3 Review of Lead Auditor's Qualifications - Currently Certified -

Checklists 1, 2 and 3 Review candidate's records using the checklists designated for i Section 5.5.2, above. If his initial certification was valid,  !

conduct a review as noted below, on the continuity of the can- i didate's maintenance of his certification (i.e., Maintenance of Proficiency, ANSI N45.2.23, Section 3.2).

Determine if the candidate maintained his proficiency through one or more of the following:

Regular and active participation in the audit process.

l OR, Review and study of codes, standards, procedures, and other l documents related to QA programs and program auditing. J OR, participation in training programs.

AND, the previous organization's management conducted annual assessments and documented the extension of his certification.

If the candidate meets the above-noted requirements, he may be certified as an SLI Lead Auditor. j 5.5.4 Requalification of Lead Auditors (ANSI N45.2.23, Section 3.3) - {

Checklists 1 and 2 l If the candidate has failed to maintain his proficiency for a  ;

period of two years or more, he is to be requalified with i refresher training, reexamination and participation as an Auditor in at least one nuclear QA audit. The checklists noted in Section 5.5.2, above are also completed. J l

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Attachment A Procedure NO. LRP-5 <

Page 10 of 15 AUDil FlpOING REPORT Date Issuedp {g } g jo:y, ~~

Report Number: AFR-01 PROJECT AUDITOR DATE DISCUSSED WITH CONTROLLING DOCUMENT, SECTION, PARAGRAPH, ISSUE DATE, REVISION REQUIREMENT DIS 0tEPANCY REC 0844 ENDED ACTIONS - INVESTIGATIVE RE(XW44 ENDED ACTIONS - REMEDIAL REC 0pe4 ENDED ACTIONS - CORRECTIVE ACTION TO PREVENT RECURRENCE APPROVED BY (Lead Auditor) DATE SUOMITTED TD (Rep, of Audited Organization)

VERIFICATION OF (X)RRECTIVE ACTION (Ploese provide documentetton for review)

Signed Date FlpOING REPORTABLE TO CLIENTf?

YES NO DETERMINED BY DATE rep %RKS 1

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~ Attachment B LRP-5 Page 1 of 2 Rev. 2 l

Page 11 of 15 l Date Issued FEB 1819EG  !

CHECKLIST 1 LEAD AUDITOR CERTIFICATION RECORD Name  !

i Credits )

1. Education (University / Degree /Date) (4 cr. max)

A-D. Undergraduate E. Graduate

2. Experience (Company / Dates) 1 (9 cr. max) l A Technical (0-5 cr.)

1 B. Nuclear Industry (0-1 cr.)

C. Quality Assurance (0-2 cr.)

i D. Auditing (0-3 cr.)

E. Nuclear QA (0-3 cr.)

F. Nuclear QA Auditing (0-4 cr.)

3. Professional Accomplishments (Certificate / Dates) (2cr. max) i A. P.E. Certificate 1

B. Society C. A.W.S. Certified Weld Inspector Cert. (1 Cr.)

4. Rights of Management (Justification / Evaluator /Date (2cr. max)  !

1 4

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i TOTAL Minimum 10 required I

1

Attachment B LRP-5 Page 2 of 2 Rev. 2 Page 12 of 15 4

Date Issued FEB 181ccG CHECKLIST 1 LEAD AUDITOR CERTIFICATION RECORD (cont'd.)

Name i

5. Audit Communication Skills Evaluated By:

Name Title Date

6. Audit Training Courses (Course Title /Date)

(a.)

(b.)

(c.)

Satisfactory Audit Training Signed Title Date

7. Audit Participation (Audited Organization / Location /Date)

(a.)

(b.)

(c.)

(d.)

(e.)

8. Satisfactory Examination Results Oral Written Practical Signed Title Date Cert'tication: -

j is a qualified Lead Auditor.

Approved by:

i Date i

Certified by:

Date

Attachment C LRP-5 Page 1 of 2 Rev. 2 Page 13 of 15 Date IssuegEB 1 8 1950 Checklist 2 CONFIRMATION OF AUDIT SKILLS AUDITOR'S NAME I have personally observed the audit skilla of the above asaed editor during his performanes sa Audit No. .

My comments in this respect are provided on the following checklist of audit elements:

l CHECKLIST OF AUDIT ELEMENTS S U N/A CoFDfEhTS

1. Planning Effort 1.  !

a. Checklist preparation a.

b. Team orientation b. ,

c. Scope c.

2. Performance 2.

a. Depth and scope of interrogation a.

b. Evaluation of system through examination of objective evidence b.

c. Judgement c.

d. Preparation of findings d.

e. Perspective in evaluation of findings a.

f. Effective use of time f.

3 Did auditor terrant respect of

) audited organisation? g.

h. Did auditor adequately control audit course and pace? h.

1. Did auditor effectively direct and coordinate edit team activities? 1.

3. Euman Factors -

3. .

a. Tact a.

b. Objectivity b.

c .- Confidence c.

d. Verbal consunication d. j l

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Attachment C LRP-5 i Page 2 of 2 Rev. 2 i Page 14 of 15 j 1

Date IssuedFEB 181cg.3 l 1

Checklist 1 (Cont'd.)

CONFIRMATION OF AUDIT SKILLS I

I U N/A COMMENTS

4. Reporting 4.

1

s. Provides concise picture of the j audit as observed a.

b. Provides adequate reference to objective data b. -

c. Effective writing skills c.

I i

On the basis of these comuments I recommend this aaditor receive  !

l certifiestion as " Lead Auditor".

/ '

LEAD AUDITOR DATE On the basis of these comments I recommend this auditor receive additional training in checklist items i before certification as " Lead Auditor".

, . /

1 ITEM is LEAD AUDITOR DATE I

e 9

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Attachment D LRP-5 Page 1 of 1 Rev. 2 Page 15 of 15 Date Issued I l90 l i

1 CHECKLIST 3 RECERTIFICATION OF LEAD AUDITOR NAME OF LEAD AUDITOR:

)

A review of the candidate's records shows that his initial certification i

was valid and that the continuity of his Lead Auditor's certification has been maintained in compliance with SLI QA Program commitments. l (i.e., Maintenance of Proficiency, ANSI N45.2.23 Section 3.2).

l i It has been determined by a review of the candidate's records that he l 4

has maintained his proficiency through one or more of the following, (As i Indicated):

1 I Regular and active participation in the audit process; I

OR, Review and study of codes, standards, procedures, and

' other documents related to QA programs and program audi-ting; OR, Participation in training programs.

i i

Accordingly, the candidate meets the above-noted requirements and he is hereby recertified as an SLI Lead Auditor.

4 I

l SLI Corporate QA Manager Date i

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Procedure LRP-6 Revision 2 0fIsue DEC 3 1985 S. Levy' Incorporated Review of HL&P v B&R Litigation Record Deviation Reporting and Action Item Requests - LRP-6 Sumary of Revisions Revision No. Revision Description Rev. O Initial Issue Rev. 1 Modify DR and AIR form presentation Rev. 2 Change to Section 4.1 Add " Attachment A" to DR form Add " Attachment C" to AIR form I

Revision Authorization l Date Revision No. 2 l

l Date Issued n r. n 3 1985 m _

Approved by (SLI) .

fire,*as/r/

hh*f # "l1t!NC Approved by '

(HL&P Nuclear }

Licensing) til% i 6-k Approved by (HL&P ,/) A f Nuclear Assurance) p. A>J . /M@fff

}

Procedure LRP-6 Revision 2 Page 2 of 9 pte Issued npt 3 FM S. Levy Incorporated

Title:

Review of HL&P v B&R Litigation Record

Subject:

Deviation Reporting and Action Item Requests 1.0 Purpose To provide instructions and describe responsibilities for detecting, reporting, documenting, evaluating and correcting con-ditions adverse to the quality of litigation record review activi-ties.

2.0 Scope This procedure applies to conditions adverse to the quality of the litigation record review activity.

3.0 Definitions APPARENT DEVIATION: An apparent departure of a characteristic from specified requirenents.

DEVIATION: A clear departure of a characteristic from specific requirements.

DEVIATION REPORT (DR) Att. A: A form used to document the occurrence and subsequent review and resolution of a deviation.

ACTION ITEM REQUEST (AIR) Att. C: A form used to document an apparent deviation and'its evaluation.

CHARACTERISTIC: Any property or attribute of an item or service that is distinct, describable and measurable as conforming or non-conforming to specified quality requirements.

CORRECTIVE ACTION STATUS REPORTING SYSTEM: A data storage and retrieval system that contains summary information on Action Item Requests, Deviation Reports and Audit Finding Reports.

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, Procedure LRP-6 Revision 2 a s e DEC 3 1985 l

4.0 Procedure 4.1 General

~

It is the responsibility of litigation review participants to 1

detect and report conditions considered adverse to quality, and to follow the provisions of this procedure. The Team Leader, "

having overall responsibility for detecting, correcting and pre-venting conditions adverse to quality, need not prepare DR and AIR forms as described below. He will, however, document in his Tt/.1

file significant occurrences and actions taken. When an apparent , .

deviation is detected, it is brought to the attention of a QA i Specialist for initial review and screening to determine whether i it should be processed as a DR or an AIR.

i 4.2 Processing of DR's The litigation review participant identifies the deviation and

{ documents the deviation impact on a DR form (Attachment A).

Instructions for processing the DR form are given in Attachment B. In conjunction with a QA Specialist he evaluates the j deviation for remedial corrective action as well as for iden-

tification of corrective action to prevent recurrence. If, during the processing of the deviation, it is determined that

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, the deficiency may be reportable under 10CFR 21 requirements,~the i

Deviation Report is sent to the Team Leader and processed i

according to QAPP 16-2, S. Levy Incorporated Quality Assurance Program Manual with the deletion of the following section in i Section 5.1:

! "For purposes of complying with this Procedure, all Project i

Staff are instructed to report promptly to the Project Leader any j anomalous software or test data, or equipment malfunctions."

! The disposition of the DR will be assigned to appropriate person-nel by the Team Leader and scheduled for completion. The QA Specialist reviews and verifies the disposition made and if he concurs, closes the DR.

4.3 Processing of AIR's i The litigation review participant identifies the apparent .

deviation and documents it in part 1 of the AIR, Action Item Request form (Attachment C). The QA Specialist will determine-if remedial action is required.

4

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l Procedure LRP-6 Revision 2 Page 4 of 9 Date Issued DEC 3 1985 l 1 - If remedial action is not required, the Specialist uses the AIR  :

form to document his reasons and returns the completed form to the initiator.

- If remedial action is required and the apparent deviation is evaluated to be significant, a DR is initiated and the AIR will be closed by reference to the DR.

- If remedial action is required but the apparent deviation is not considered significant, the action is assigned to appropriate personnel by the Team Leader and scheduled for completion. Upon completion the QA Specialist reviews and verifies the action taken and, if he concurs, closes the AIR.

- If the QA Specialist cannot readily determine the significance of the apparent deviation he will assign this determination to the QA Manager, who in turn will follow the steps described above.

4.4 Tracking Status Reporting and Trend Analysis DR's and AIR's requiring corrective action are logged and tracked by a Corrective Action Status Reporting System. This system will list for each DR, AIR, and Audit Finding Report (AFR) a unique identification number, date of origination, the personnel respon-sible for resolution, a brief description, the status and sche-

! dule.

Each individual assigned to evaluate or complete action asso-ciated with a DR or AIR is responsible for reporting the status of his activities to a QA Specialist on a periodic basis until completion.

Quality trends are analyzed to furnish a basis for improvement in work performance.

4.5 Quality Status Reports The Project QA Specialist submits periodic status reports to the Team Leader and the Corporate QA Manager as required by the Project Plan. The reports contain brief, narrative descriptions of quality cssurance program progress and accomplishments; sum-maries of current problems, with their analysis and corrective action status; quality trend data; and results of progran audits and management review.

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ATTACHMENT A Procedure LRP-6_.

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1 Procedure LRP-6 Revision 2 Page 6 of 9 Date Issued DEC 3 1983 ATTACHMENT B PROCESSING OF DEVIATION REPORTS (DRs)

When Project or QA personnel detect a deviation, a Deviation Report form (Attachment A) is initiated.

1. Identification and Description (Part 1 of the Form)

This part is filled out by the individual who detects the deviation after any immediately required corrective action or notifications are performed. Where necessary, he utilizes assistance from his immediate ,

supervisor or other qualified personnel. The date and time of l occurrence, and whether or not the deviation affects a safety-related I (Q-Listed) system, structure, component or activity, are identified. A title is developed to identify the occurrence or condition. The plant system and equipment affected (if applicable) are identified. A description of the occurrence or condition is written, identifying spe-cifically what procedures, instructions, specification, limit or requirement was violated. Imediate action taken to mitigate the con-sequences or preclude the recurrence of the nonconforming condition is 1 identified. Also identified are references or , working documents that I are pertinent to the occurrence or condition; e.g., procedures, procure-ment documents, contracts, specifications, instructions, drawings, etc.

j The originator signs and dates the Deviation Report and submits it to his supervisor for approval. If he approves, he identifies the indivi- l

dual to whom the DR is to be forwarded for further processing and signs i

' and dates the DR and forwards it with supporting documentation to the Project QA Specialist.

The Project QA Specialist assigns a unique identifying number, logs it, and forwards the DR to the individual identified for further processing.

J A copy of the DR is sent to the Corporate QA Manager for incorporation l l

into the Project Corrective Action Status Reporting System. If the supervisor disapproves the DR, he documents his reasons for disapproval

' in Part 3, returns the DR to the originator and forwards a copy through the Project QA Specialist to the Corporate QA Manager for information.

The DR need not be numbered and logged. However, if it has been num-

.i bered and logged, it must be closed out according to Section 5 Completion Review, below.

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Procedure LRP-6 Revision 2 _ . . . .

Page 7 of 9 Date Issued DEC 3 25

2. Reportability (Part 2 of the Form)

Upon receiving a Deviation Report for evaluation and disposition, the Responsible Individual first reviews it for reportability to the client.

If it is considered potentially reportable, he immediately transmits the DR to the Team Leader for processing according to QAPP 16-2. If the occurrence is not reportable, the individual receiving the DR for eva-luation and disposition assigns an evaluator (it may be himself), and an evaluation due date which is indicative of the nature of the DR, and the time required for resolution. Consideration is given to the need to maintain Project schedule. He then forwards the DR to the Project QA Specialist who updates the data in the log, sends a copy to the Corporate QA Manager for Corrective Action Status Reporting System updating, and forwards the DR to the assigned evaluator.

3. Evaluation and Disposition (part 3 of the Form)

The evaluation of the Deviation Report consists of an analysis of the pertinent information related to the event. From this analysis, the cause, including all contributing factors, is identified. The remedial  !

corrective action (action required to correct the specific event) and 1 the corrective action required to prevent recurrence of the event are l detailed on the DR, and additional sheets, as necessary. Corrective l action to prevent recurrence must be directed at the cause of the event. '

Upon completion of the evaluation and definition of required corrective l action, the evaluation and disposition are reviewed and approved by the I evaluator's supervisor who determines what, if any, additional correc-tive action must be completed before reliance is placed on affected systems.

I The reviewer identifies the required date for completion of each correc- I tive action and the individual assigned to complete each corrective l action. The. reviewer signs and dates the DR to indicate approval of the  !

proposed corrective action. The DR is sent to the Project QA Specialist I for updating the log and a copy is sent to the Corporate QA Manager for  ;

Corrective Action Status System updating. The Project QA Specialist I forwards the DR to the assignee for completion of the corrective action.

For deviations of a more complex nature, multiple corrective actions may be assigned. The Deviation Report is forwarded to a single individual responsible for overall coordination of the corrective action.

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Procedure LRP-6 Revision 2 .

Page 8 of 9 Date Issued DEC 3 1983

4. Completion (part 4 of the Form)

Completion of required corrective action is accomplished using the Deviation Report form as a reference. The DR remains open until all corrective actions are complete. Upon receipt of the Deviation Report with supporting documentation, the assigned individual performs the identified corrective action. he is responsible for reporting the sta-tus of the corrective action on a monthly basis to the Project QA Specialist who transmits the information to the Corporate QA Manager.

The assigned individual documents the complete.1 action on the Deviation Report. If the actual corrective action accomplished differs from that specified in Evaluation and Disposition, the differences are noted. The  :

individual completing the corrective action signs the DR and forwards it j together with supporting documentation to his supervisor who reviews it for acceptability. If not acceptable, the DR is returned to the  ;

assigned individual for further corrective acticn. The DR is then for-  ;

warded to the Project QA Specialist for logging of completion and a copy I is sent to the Corporate QA Manager for review. Reliance may be placed on systems to perform their intended safety funccion prior to QA review.

When assembled, all documentation which supports the completion of a Deviation Report is attached to the DR. The DR and attached documen-tation is submitted to the Corporate QA Manager.

5. Completion Review (Part 4 of the Form) l Upon receipt of the Deviation Report with supporting documentation attached or referenced, the Corporate QA Manager reviews it for accep-tability. If the DR is acceptable, then he signs Part 4 of the DR form and updates the Corrective Action Status Reporting System to indicate that the Deviation report is 100% complete. The original DR and sup-porting documentation is filed in Project files in accordance with the Project Document Processing Matrix. If it is not acceptable, the  !

Deviation Report is returned to the appropriate individual for resolu-  !

tion of the discrepant areas. If agreement cannot be reached, the issue is pursued with the President of SLI. I i

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ATTACHMENT C Procedure LRP-6 Rev. 2 . . . .

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i APPENDIX D f

Appendix D~. lists the Project documents approved by HL&P for reference on Disposition Forms to demonstrate STP cognizance of the substance of' an assertion or to demonstrate that -the assertion is fac-tually erroneous.

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DOCUMENTS TO BE REFERENCED ON DISPOSITION FORMS A reference to one of the following documents or categories of documents, sufficient to support the disposition, must be included on the Disposition Form whenever the disposition statement concludes that the substance of the assertion has been previously identified by STP or that the assertion is factually erroneous. [ Dispositions not safety-related must use the reference documents given in LRP-1, Attachment 8.1 (Criteria for Safety Determination)]:

1. The STP Final Safety Analysis Report (FSAR)

2. HL&P Incident Review Committee (IRC) File material, including 10 CFR 50.55(e) reports

3. NRC Inspection Reports and HL&P responses to these

4. Bechtel Energy Corporation (BEC) Design Criteria (DC) for the South Texas Project

5. Controlled South Texas Project engineering documents. These include, among others:

A. Piping and Instrument Drawings (P&!Ds), Single-Line Drawings, and General Arrangement Drawings

8. Piping Isometric Drawings C. Design Specifications, Criteria, and Calculations D. Stress Reports E. SSC Analyses F. Brown & Root Technical Reference Documents (TRDs) k i

D-1

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6. The following materials related to the April 30, 1980 Order to Show Cause and HL&P's responses thereto: 5 A. NRC Special Investigation of Construction Activities, dated April 30, 1980, and attached materials B. HL&P's May 23, 1980 reply to the NRC's April 30, 1980 Order to Show Cause, and attached materials C. Reports prepared by '.HL&P, B&R, and their consultants on Show Cause issues, specifically:

1. Expert Committee's Final Report on Adequacy of Category I Structural Backfill, South Texas Project Electric Generating Station to Brown-& Root, Inc., by A. J.

Hendron, Jr., H. Bolton Seed, Stanley D. Wilson, dated January 30, 1981 ii. Interim Report to Brown & Root, Inc., on Adequacy of

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Category I Structural Backfill, South Texas Project Electric Generating Station byA. J. Hendron, Jr., H.

Bolton Seed, Stanley D. Wilson, dated July 12,.1980 iii. Letter to J. L. Hawks of Brown & Root, Inc., from J. F.

Artuso of Construction Engineering Consultants, Inc.,

titled: Inspection and Testing for Show Cause Item 3b South Texas Nuclear Power Plant, dated July 25, 1980 iv. Final Report of Safety-Related Concrete Show Cause Item 3(b) South Texas Project (no date or author on report)

v. Review of Safety-Related Welding at South Texas project Electric Generating Station, Final Report, dated April 1981 (no author listed) I 1

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7. Technical Evaluation of Anchor Bolts and Imbedded Rods, HL&P Report on Anchor Bolts

8. B&R and HL&P Deficiency Trending Reports

9. STP Fire Hazards Analysis Report

10. STP Technical Specifications ,

11. Reports of HL&P Engineering Assurance covering specific areas of STP design

12. STP Nonconformance Reports (NCRs) providing they have been vali-dated

13. STP Field Change Requests (FCRs)

14. STP Corrective Action Reports (CARS)

15. STP Standard Deficiency Reports (SDRs)

16. STP Deficiency Notices (DNs)

17. STP Deficiency Evaluation Forms (DEFs)

18. STP Deficiency Evaluation Reports (DERs)

19. STP Audit Deficiency Reports (ADRs)

20. STP Engineering Change Requests (ECRs)

21. STP Potential Change Notices (PCNs), provided that they have been signed by an HL&P Project Manager

22. STP Design Change Notices (DCNs), provided that they have been signed by an HL&P Project Manager

23. Formal memos and letters numbered to the standard STP numbering system (e.g., STP-HL-BR-xxxx, etc.)

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24. STP-numbered Purchase Orders and Subcontracts

25. Reports requested and received by HL&P on specific STP design or construction issues

26. NRC Commitment Status Report

27. Licensing Commitment Tracking System for Inspection Report Findings Documents other than those listed above may be referenced on the Disposition Form to supplement information provided by those documents.

However, a Disposition Form must reference those documents listed above which are sufficient to demonstrate independently that the STP has iden-tified the substance of the assertion or that the assertion is factually erroneous. _

\

The version of the Final Safety Analysis Report for the South Texas Project Units 1 and 2 used by SLI was current through Amendment 52, dated November 15, 1985.

The Bechtel Design Criteria Manual for the South Texas Project used '

by SLI was current through revisions of July 31, 1985.

D-4

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